DOT Pipeline Compliance News

March 2002 Issue

In This Issue

Advisory Notice; Enhancing the Security of Hazardous Materials in Transportation

The DOT has issued a notice that advises shippers and carriers of voluntary measures to enhance the security of hazardous materials shipments during transportation. The notice addresses personnel, facility, and en route security issues and includes contact points for obtaining additional, more detailed information. In the wrong hands, hazardous materials pose a significant security threat, particularly those that may be used as weapons of mass destruction. Persons who offer, transport, or store hazardous materials in transit should review their security measures and make any necessary adjustments to ensure the security of hazardous materials shipments. To assist you in performing appropriate risk assessments, RSPA has posted a Risk Management Self-Evaluation Framework on their website (

FOR FURTHER INFORMATION CONTACT: Susan Gorsky, Office of Hazardous Materials Standards, Research and Special Programs Administration, telephone (202) 366-8553. The full notice is available on RCP’s website here.

Natural Gas Transmission and Storage Facilities NESHAP Correction to a Correction

Editor’s note: we don’t make this stuff up!

On June 17, 1999, EPA issued the national emission standards for hazardous air pollutants (NESHAP) from Oil and Natural Gas Production Facilities and the national emission standards for hazardous air pollutants from Natural Gas Transmission and Storage Facilities (Oil and Gas NESHAP). The NESHAP requires new and existing major sources to control emissions of hazardous air pollutants (HAP) to the level reflecting application of the maximum achievable control technology. On June 29, 2001, EPA issued technical corrections to clarify intent and correct errors in the NESHAP. This technical correction will correct an error that was made in the technical correction. The correction removes subparagraph §63.1270(a)(1)(iv) that mistakenly remained in the June 29, 2001 technical corrections. In that action a single equation was added to simplify a four-step process to calculate natural gas throughput. The deletion of this subparagraph will avoid confusion and make it clear that only the single equation added in the June 29, 2001 action is used in determining natural gas throughput.

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.
Click Here.

Clean Slate Planned at Office of Pipeline Safety

On February 19, 2002, OPS administrator Ellen Engleman told the House Subcommittee on Highways and Transit that she is working diligently to better enforce regulatory mandates that government officials and consumer groups say have been neglected for far too long. “I am determined to wipe the slate clean within 12 months,” she said. “At the beginning of my tenure, there were 65 outstanding mandates and recommendations. We are making progress on the congressional mandates, completing four important rulemakings last month on integrity management, repair, and accident reporting and corrosion control for hazardous liquid pipelines.” She predicted that by month’s end OPS will have dealt with nearly 50% of the remaining National Transportation Safety Board, Inspector General, and General Accounting Office recommendations in a “meaningful way.”

So – expect more rulemakings from the DOT / OPS in the near future! For example, the proposed rule for natural gas pipeline integrity management may be issued in April or May, 2002.

Revisions to Louisiana State Pipeline Safety Regulations

The State of Louisiana has revised their pipeline safety regulations to align them with current Federal pipeline safety standards. The revisions can be downloaded from RCP’s website here.

Accident Reporting Revisions – Effective Date Correction

The Research and Special Programs Administration published a final rule in the Federal Register on January 8, 2002, regarding changes to the reporting requirements for hazardous liquid pipeline accidents (reference our January, 2002 newsletter). The effective date of this rule was inadvertently published as January 1, 2002. The correct effective date of this final rule is February 7, 2002. The DOT is encouraging operators to use the new reporting criteria for spills starting January 1, 2002, but the new criteria are not officially required to be used until February 7.

Acquiring a pipeline?

RCP can provide due diligence audits to help you ensure that potential compliance issues have been addressed before the sale is final. Click Here.

Workshop Schedules for EPCRA/TRI Training: Spring 2002

EPA will conduct EPCRA/TRI Training workshops across the country during the spring of 2002. These workshops are intended to assist persons preparing their annual reports on release and other waste management activities as required under sections 313 of the Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) and section 6607 of the Pollution Prevention Act of 1990 (PPA). These reports must be submitted to EPA and designated state officials on or before July 1, 2002.

FOR FURTHER INFORMATION CONTACT: Priscilla Evans, Workshop Coordinator (202) 260-9124, for specific information on this notice. Information concerning the EPCRA/TRI Training workshops is also available on EPA’s web site at

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