DOT Pipeline Compliance News

June 2002 Issue

In This Issue

Advisory Notice Regarding Safe Excavation Practices

On May 17, 2002, RSPA issued the following advisory notice to operators of natural gas and hazardous liquid pipelines to remind them of the importance of safe excavation practices. It makes reference to The Common Ground Study, which can be viewed on line at

Advisory Bulletin (ADB-02-01)

To: Owners and Operators of Natural Gas and Hazardous Liquid Pipeline Systems
Subject: Notification to Stress the Importance of Safe Excavation Practices

Advisory: The arrival of warmer weather coincides with a significant increase in construction activity both by professional excavators and home owners and renters. To protect excavators and private citizens from injury and to guard the integrity of buried pipelines and other underground facilities, OPS reminds all concerned to implement the best practices of the Common Ground Study and the four steps of the Dig Safely Campaign.

  • Call Before You Dig
  • Wait the Required Time in Your State for Operators to Mark Their Facilities
  • Observe Marks Indicating the Presence of Facilities When You Dig
  • Dig With Care-protect both yourself and the facilities where you are digging.

We ask pipeline operators to undertake the following steps as part of their damage prevention efforts:

  • increasing their vigilance on right-of-way inspections;
  • reviewing their own procedures for following up on locate requests;
  • ensuring that operator employees and contract employees follow Best Practices; and
  • increasing outreach efforts to the excavator community during the spring season.

O&M Manual Up-To-Date?

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EPA Promotes Environmental Management Systems

Environmental Protection Agency Administrator Christie Whitman has issued the Agency’s Position Statement on Environmental Management Systems (EMS). The statement promotes broader use of the systems, which are effective management tools to help companies and other organizations fulfill their environmental responsibilities.

The use of EMS complements needed regulatory controls and enables a facility to comprehensively manage the environmental footprint of its entire operation. This includes unregulated aspects such as energy, water use, climate change, odor, noise, dust, and habitat preservation. It encourages pollution prevention through source reduction and fosters continuous improvement of the facility’s environmental performance. An EMS is viewed as a valuable tool for accomplishing EPA’s mission, because they apply a multi-media approach, help facilities assure compliance, and promote cost savings, operational efficiency and improved supplier performance.

The position statement signed by the Administrator commits EPA to leading by example. The agency will implement EMS in its own facilities and operations, while encouraging widespread use of EMS across other institutions and organizations. The Agency is also working with state and local governments to promote EMS. In addition, the agency will support training and research on the costs and benefits of the systems.

The position statement may be downloaded HERE.

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Upcoming RCP Seminars

RCP will conduct a 1 day workshop on Pipeline Integrity Management on July 22 in Houston. This one day workshop is an excellent introduction to the Pipeline Integrity Management regulations, and has been scheduled for the day prior to OPS’s PIM workshop in Houston (note that the OPS workshop will assume that the attendees already have a good understanding of OPS’s PIM regulations). This workshop presents a detailed analysis of the recent federal Pipeline Integrity Management regulation and the management programs / elements that it requires. The latest PIM inspection checklist will also be distributed and discussed. We will also review recent state initiatives and other proposed rules on pipeline integrity management. We received very positive feedback from the other Pipeline Integrity Management workshops that we have conducted, and expect this session to fill up rapidly. Some companies have chosen to send their entire risk assessment team to this seminar, as a way of kicking off their internal risk assessment process. Additional information is available on our website HERE.

OPS workshop on Pipeline Integrity Management

OPS will conduct a workshop on Pipeline Integrity Management on July 23, 2002, from 8 a.m. to 5 p.m., and July 24, 2002, from 8 a.m. to noon, at the J.W. Marriott Hotel, 5150 Westheimer Road, Houston, Texas 77056 (tel: 713-961-1500 fax: 713-961-5045). The purpose of this workshop is to assist operators in learning where improvement in integrity management is needed, and what means are available to achieve these improvements. On day 1, OPS will present its findings from the “quick hit” inspections conducted from February through April 20. This will include OPS’s assessment of operators’ progress in identifying pipeline segments that could affect high consequence areas (HCAs). OPS will also comment on its plans for conducting the Comprehensive Integrity Management Program Inspections, set to begin in August 2002. On day 2, OPS will provide a forum for the pipeline industry to share and discuss noteworthy integrity management practices that achieve compliance with the rule. Emphasis will be in areas in which OPS believes improvement is needed. No later than June 10, 2002, rooms may be reserved within a block identified as “USDOT/IMP Meeting Block”. For event planning purposes, please register via the instructions given at The website provides links to other useful information (including a meeting agenda, once available) and enables viewers to submit questions to OPS about the workshop. The full notice can be downloaded from RCP’s website HERE.

Acquiring a pipeline?

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Pipeline Safety Reports of Abandoned Underwater Pipelines

The Pipeline Safety Act (49 U.S.C. 60108(c)(6)(B)) directs the Secretary of Transportation to require operators of an offshore pipeline facility or a pipeline crossing navigable waters to report the abandonment to the Secretary of Transportation in a way that specifies whether the facility has been abandoned properly according to applicable Federal and State requirements. RSPA’s regulations for abandonment reporting can be found at 49 CFR 192.727 and 195.402. This notice requests public participation in the Office of Management and Budget (OMB) approval process regarding the renewal of an existing Research and Special Programs Administration’s (RSPA) collection of information for Pipeline Safety Reports of Abandoned Underwater Pipelines. Specifically, public comment is requested on ways to minimize the burden of this collection of information on the public, along with other factors.

RSPA estimates the approximately 400 gas and hazardous liquid pipeline operators will spend a total of 2,400 hours providing this information. Comments are invited on: (a) The need for the proposed collection of information for the proper performance of the functions of the agency, including whether the information will have practical utility; (b) the accuracy of the agency’s estimate of the burden of the proposed collection of information including the validity of the methodology and assumptions used; (c) ways to enhance the quality, utility and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on those who are to respond, including the use of appropriate automated, electronic, mechanical, or other technological collection techniques.

Comments on this notice must be received by July 19, 2002 to be assured of consideration (docket number: RSPA-98-4957). FOR FURTHER INFORMATION CONTACT: Marvin Fell, (202) 366-6205, or write by e-mail to All timely written comments to this notice will be summarized and included in the request for OMB approval. All comments will also be available to the public in the docket.

Air Permit Needs?

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Development of Consensus Standards on Pipeline Public Awareness Programs

Editor’s note: The following is reproduced essentially verbatim from the May 15, 2002 Federal Register, since many of our readers are probably interested in the complete notice.)

Trade associations for the natural gas and hazardous liquid pipeline industry are working together to develop consensus standards to expand the public awareness programs that pipeline operators conduct, and to further involve the local communities in ensuring pipeline safety. This notice provides information about how the public can participate in this consensus standard-setting process. The Research and Special Program Administration’s (RSPA) Office of Pipeline Safety (OPS) is committed to improving the public education programs that are a part of the pipeline safety public awareness programs. Public participation is being sought as part of this standard-setting for industry public awareness programs, with the expected result of improved public education regarding pipeline safety.

Current Federal regulations require that pipeline operators conduct public education campaigns so that members of the public, excavators, residents along pipeline rights-of-way, emergency responders and local officials understand what to do in a pipeline emergency. OPS has encouraged pipeline operators to review existing programs and to make needed improvements. The National Transportation Safety Board has also issued a recommendation urging that gas and hazardous liquid pipeline operators increase public education about pipeline safety operations.

In response to concerns raised by RSPA, the American Petroleum Institute (API) has initiated a revision of its Recommended Practice (RP) 1123, Development of Public Awareness Programs. This document was originally issued for use by API members which transport petroleum and other hazardous liquids. However, the need for public education standards extends beyond hazardous liquid operators. To promote a standardized approach to public education among pipeline operators, OPS encouraged natural gas pipeline operators to work with their colleagues in the liquid pipeline industry on the API revision of recommended practice. The recommended practice, upon completion of this consensus standard-setting process, will be assigned a new ANSI identification number, and will be referred to in that manner in all future correspondence.

The Interstate Natural Gas Association of America, the American Gas Association and the American Public Gas Association have joined API in this effort. This collaborative process will bring a measure of consistency to such programs throughout the industry, and will expand the effort to include public education not solely of pipeline operators, but of all relevant stakeholders. However, this revised recommended practice would apply to existing pipelines only.

RSPA is interested in the success of this effort because OPS had already begun work in the area of public education. In the fall of 2000, at the request of the OPS Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC), OPS formed a group with equal representation from government, industry and public sectors to explore this issue. OPS also held a well-attended public meeting in February 2001 to solicit input on the information needs of the public and other audiences.

The revision of the recommended practice will provide guidelines that operators can use to develop or improve existing public awareness and community outreach programs. In advance of this revision, API surveyed a number of its members to determine the effectiveness of existing public awareness programs and to identify areas which required improvement. The results of this survey are being used to help guide the revision of the recommended practice, which is expected to be complete by the end of 2002.

The API has created a Web site, to obtain informal, early feedback and to solicit public input. OPS hopes that the public will take this opportunity to provide its comments. It is important to note that the American National Standards Institute (ANSI) will also provide the opportunity for formal Notice and Comment on the revision of the recommended practice. OPS urges interested parties to submit their remarks on the completed revision to ANSI.

OPS, as the Federal government representative, and the National Association of Pipeline Safety Representatives (NAPSR), the body representing the State pipeline safety agencies, are participating in this process as observers. After industry has finalized the revision, OPS will decide whether or not to adopt it as a regulatory requirement. Alternatively, OPS may adopt only those portions of the document that meet its needs. While OPS has encouraged this process, the decision on whether to adopt this standard has not been pre-determined. If OPS decides to incorporate the revised recommended practice by reference, a Notice of Proposed Rulemaking will be published in the Federal Register for public comment.

FOR FURTHER INFORMATION CONTACT: Mary-Jo Cooney, OPS, (202) 366-4774.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
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Integrity Management FAQ

Editor’s note: This and all other Frequently Asked Questions about the Pipeline Integrity Management rule can be found at:

12.6 Will OPS review operator notifications and formally respond to the operator? Will OPS communicate responses to specific company notifications to the broader industry?

OPS expects to review all notifications received from operators. A centralized process involving input from the OPS Regions will be used to assure thorough review. OPS will coordinate review of notifications affecting intrastate pipelines subject to the rule with the States, as appropriate.

A summary of each notification (omitting any sensitive information) will be posted on this web site, along with the status of their review (pending, accepted, denied). This will allow the public to see where operators are deviating from the rule, and will also allow operators to see notifications from other operators. Operators who submit notifications will receive e-mail informing them any time the review status of their notification changes. OPS will respond any time it determines that the actions proposed in a notification are unacceptable, describing the basis for its conclusion.

Operators subject to specific State rules and regulations that require notification must also comply with those requirements.

Bill Byrd signature
W. R. (Bill) Byrd, PE
RCP Inc.