DOT Pipeline Compliance News

May 2004 Issue

In This Issue

Notice of Workshop on Gas Pipeline Integrity Management

The Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) and the National Association of Pipeline Safety Representatives (NAPSR) will cosponsor a workshop on Tuesday, May 11, 2004, from 8 a.m. to 5:30 p.m. and Wednesday, May 12, 2004, from 8 a.m. to Noon to discuss the Gas Pipeline Integrity Management final rule issued on December 15, 2003. The workshop will provide a detailed review and discussion of gas pipeline integrity management program requirements. Comments and issues discussed at the workshop will help RSPA/OPS and NAPSR implement oversight of operators’ compliance with the gas pipeline integrity management rule. RSPA/OPS and NAPSR will hold another workshop in 2004 to provide further guidance on the oversight process to be used. OPS will also provide written guidance material to help operators prepare for compliance.

This meeting is open to all interested parties. Attendees will be provided the opportunity, at scheduled times during the workshop, to ask questions or make short statements on the topics under discussion. Operators of natural gas transmission pipelines are urged to attend either in person or to observe the workshop via the Internet. RSPA/OPS will webcast this meeting. To facilitate meeting planning and to obtain additional information regarding the webcast, advance registration for the meeting is strongly encouraged and can be accomplished online at the following Web site: primis/ Internet links to the webcast will also be available through this Web site, or from the front page of the OPS Web site: Those planning to “attend” this meeting through the webcast are strongly encouraged to review our “tips” for ensuring successful viewing in advance, as well as to register through our Web site. Registration both ensures that we can accommodate all attendees and provide additional information to them via the internet. The deadline for online meeting registration is May 5, 2004. Walk-in registration will be accommodated on a first-come, first-served basis.

The workshop will be held at the Westin Galleria, 5060 West Alabama, Houston, Texas, Phone: 713-960-8100; fax: 713-960-6549. For discounted rates, please refer to the USDOT Gas IMP Workshop block when making reservations. The deadline for reserving accommodations is April 19, 2004. For additional information on hotel accommodations, contact Janice Morgan at 202-366-2392 or

Integrity Management Plan Up-to-Date?

RCP has the tools and expertise to develop comprehensive Integrity Management Plans for both liquid and gas pipelines. Click Here if you would like information on RCP’s Integrity Management Services and receive a copy of our FREE Integrity Management CD.

Proposed Rule Re: Movement of Oil and Gas as Required by the OCS Lands Act

The MMS requests comments and any suggestions to assist in potentially amending the regulations regarding how the Department of the Interior (DOI) should ensure that pipelines transporting oil or gas under permits, licenses, easements, or rights-of-way on or across the Outer Continental Shelf (OCS) “provide open and non-discriminatory access to both owner and non-owner shippers” as required under section 5(f) of the Outer Continental Shelf Lands Act (OCSLA). The MMS is the bureau in the DOI charged with fulfilling the Secretary of the Interior’s (Secretary) responsibility under the OCSLA. The MMS is committed to making changes that reflect the Secretary’s “4C’s” philosophy of “consultation, cooperation, and communication all in the service of conservation.” The MMS is issuing this Advance Notice of Proposed Rulemaking to give the public and interested parties an opportunity to provide input to the MMS regarding what actions or processes the public and interested parties believe the Secretary should initiate to ensure that pipelines provide open and non-discriminatory access.

You must submit your comments by June 11, 2004, as shown: By mail: Director, Minerals Management Service, Attention: Policy and Management Improvement, 1849 C Street, NW., Mail Stop 4230, Washington, DC 20240-0001. By personal or messenger delivery: 1849 C Street NW., Room 4223, Washington, DC 20240-0001. The MMS is currently connected to the internet and able to receive e-mails. However, before e-mailing your comments during the comment period to ensure the MMS is connected, please contact Mr. Martin Grieshaber at 303-275-7118.

For more information, contact Martin Grieshaber at 303-275-7118 for information relating to the purpose of the meetings, the issues raised in this document, or for information relating to the rulemaking process.

Need to update your Public Awareness Program?

RCP can help develop your updated plan to meet API RP 1162 standards, and provide turnkey implementation, mail-outs, evaluations, and tracking of your program. For more information call or Click Here.

Taking Marine Mammals Incidental to Conducting the Precision Strike Weapon (PSW) Testing and Training by Eglin Air Force Base in the Gulf of Mexico

Editor’s note: The following article doesn’t have anything to do with our newsletter purpose, other than to point out that, in the United States, you need a permit, by golly, before dropping any bombs near our marine mammals!!!

National Marine Fisheries Service (NMFS), National Oceanic and Atmospheric Administration (NOAA), has received a request from Eglin Air Force Base (Eglin AFB), for authorization to harass marine mammals incidental to testing and training during Precision Strike Weapons (PSW) tests in the Gulf of Mexico (GOM), a military readiness activity. As a result of this request, NMFS is proposing to issue a 1-year incidental harassment authorization (IHA) to take marine mammals by Level B harassment incidental to this activity and will propose regulations at a later time that would govern the incidental taking of marine mammals under a Letter of Authorization (LOA) issued to Eglin AFB for a period of up to 5 years after the 1-year IHA expires. In order to issue IHAs and promulgate regulations and LOAs thereunder, NMFS must determine that these takings will have a negligible impact on the affected species and stocks of marine mammals. NMFS invites comment on Eglin AFB’s application, NMFS’ preliminary determinations on the impact of the activity on marine mammals and suggestions on the content of the regulations.

PSW missions involve air-to-surface impacts of two weapons, the Joint Air-to-Surface Stand-off Missile (JASSM) AGM-158 A and B and the small-diameter bomb (SDB) (GBU-39/B) that result in underwater detonations of up to approximately 300 lbs (136 kg) and 96 lbs (43.5 kg, double SDB) of net explosive weight, respectively.

There are 29 species of marine mammals documented as occurring in Federal waters of the GOM. Information on those species that may be impacted by this activity are discussed in the Eglin AFB application and the Draft EA. A summary of that information is provided in this section.

Editor’s further note: The full federal register article (April 22, 2004, pages 21816 – 21825) has a lot of information about the bombs and how they work, if you are in to that kind of thing….

Need A Security Plan or Audit?

We have the expertise to develop a security plan and perform risk assessments for pipeline and terminal facilities to meet recent DOT Hazmat Transportation & Pipeline regulations. We can also assist you in USCG security plans for dock facilities and vessels. Please contact Jessica Roger for more information.

DOT Makes Off-Shore Pipeline Report Available

The DOT has this week posted a 1998 report on burial, inspection and risk to off-shore pipelines in the Gulf of Mexico. This Texas Transportation Institute study examined burial depths, various sub-sea inspection techniques and the effects of weather and erosion on pipelines, as well as other risk factors. Given the current interest in off-shore pipeline safety, it might be worth examining. It may be found at

RCP’s Fantastic 1-Page Version of New SPCC Regulation

The deadline for SPCC Plan revisions is fast approaching, February 17, 2006! RCP has developed a 1-page version (in tiny type) of the new SPCC regulations, to be revised as per the April 17, 2003 rule modification. To receive a complimentary copy along with a CD of valuable SPCC Reference Materials Click Here to request additional information.

MMS Announces Availability of Revised Outer Continental Shelf Leasing Map

The Outer Continental Shelf Leasing Map in the Central Gulf of Mexico Planning Area is on file and available for information only, in the Gulf of Mexico OCS Regional Office, New Orleans, Louisiana. In accordance with Title 43, Code of Federal Regulations, this map is the basic record for the description of mineral and oil and gas lease sales in the geographic area it represents.

Leasing Maps and OPDs may be obtained in two digital formats: .gra files for use in ARC/INFO and .pdf files for viewing and printing in Acrobat. Copies are also available for download at

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.

OQ Audit Results

We’d like to share the initial results from one Operator Qualification program audit that recently made the news. Since the pipeline company has not had a chance to respond to the alleged deficiencies, we’ve omitted their name from the following text. But the citations are instructive, and should provide food for thought for other pipeline operators who may be facing OQ audits:

In its March 11 notice to the company, the agency (OPS) levels seven specific allegations that the company failed to abide by the new training and qualification standards, two of which involve irregularities in how the company tests employee qualifications for specific tasks.

One claims that exams given to check whether workers are qualified to investigate gas leaks “used the exam key, with the correct answers underlined and bolded, not the unmarked exam provided in the training module as a sample.”

Another states, “There were instances found where a qualification test was completed by an individual other than the one being qualified.”

The agency’s notice also says a field inspection turned up a pipeline worker doing welding work for which he was not properly qualified and alleges a general deficiency in the company’s employees’ training and qualification to recognize and address “abnormal operating conditions.”

Other alleged violations include numerous instances of missing or incorrect records; missing signatures or other pertinent information on qualification tests; and instances of workers apparently having completed skills evaluation for various tasks without official confirmation.

O&M Manual Up-To-Date?

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Renewal of Existing Information Collection by OPS; Request for Comments

The Research and Special Programs Administration (RSPA), Office of Pipeline Safety (OPS) published a notice in the Federal Register on February 13, 2004 (69 FR 7283) requesting public comments on renewal of an information collection, Reporting of Safety-Related Conditions on Gas, Hazardous Liquid and Carbon Dioxide Pipelines and Liquefied Natural Gas Facilities. No comments were received. This notice requests approval of the renewal by the Office of Management and Budget (OMB) and additional comments from the public.

Comments on this notice must be received no later than June 3, 2004 and should identify the docket number RSPA-98-4957. Comments must be mailed directly to Office of Management and Budget, Office of Information and Regulatory Affairs (OIRA), 726 Jackson Place, NW., Washington, DC 20593, ATTN: Desk Officer for the Department of Transportation.

For more information, contact Marvin Fell, Office of Pipeline Safety, Research and Special Programs Administration, U.S. Department of Transportation, 400 Seventh Street, SW., Washington, DC 20590, (202) 366-6205, or by fax to (202) 366-4566, or via e-mail at

TSA Working on Transportation Worker Credential

The Transportation Security Administration is preparing a Transportation Worker Identification Credential (TWIC) program to create a universal credential to be used as a means to enhance access control for individuals requiring unescorted access to secure areas of the national transportation system. This program is intended to apply to pipelines. Comments are due by June 4, 2004. TSA specifies that the participation in the program is voluntary, although it appears to be voluntary by facility participant, not by employee. Volunteers will provide TSA with employee information such as (a) Individual’s name, (b) other identifying data to include address, phone number, social security number, date of birth, and place of birth, (c) company, organization, or affiliation, (d) biometric data and digital photograph, and (e) access level information. In a second phase, random surveys will be distributed to employees at participating facilities to judge employee satisfaction and credential effectiveness. The information collected under this proposal will be used to operate and evaluate the TWIC system during the Prototype Phase. For the complete stakeholder briefing on TWIC go to The complete proposal is available on RCP’s website here.

TSA Plans Facility Access Survey

In a related development, the Transportation Security Administration issued request for comments this week on a new effort aimed at gathering facility access information on pipelines, as well as other transportation modes. Comments are due by June 4, 2004. TSA is in the process of testing the Transportation Worker Identification Credential (TWIC) Program concept, which, if approved, will provide for a single, uniform credential nationwide for transportation workers who require access to secure transportation areas. In the Technology Evaluation phase of the TWIC Program, TSA evaluated five card technologies in many types of physical and logical access transactions, and in the Prototype phase, it intends to evaluate a broad range of business processes as they relate to credentialing, identity, and identity management. The information collected for the TWIC National Survey differs from these pilot programs in that it will be used as a means to develop a predictive model of the current access control technology infrastructure at transportation sites across the nation, should the TWIC be approved for implementation. The bulk of the information to be collected in the National Survey pertains to the facility (i.e., number of access points, badged population, etc.), not to individuals. This information will be used to help determine implementation approaches for the TWIC Program at transportation facilities and modes across the country that differ by type and size (e.g., aviation, rail, maritime, and pipeline). The complete proposal is available on RCP’s website here

Failures of Excess Flow Valves (EFV’s) in Hazardous Materials Service

The Environmental Protection Agency (EPA) has recently issued an Alert as part of its ongoing effort to protect human health and the environment by preventing chemical accidents. The alert is available on RCP’s website here. Major industry and commercial accidents cannot be prevented solely through regulatory requirements. Rather, understanding the fundamental root causes, widely disseminating the lessons learned, and integrating these lessons learned into safe operations are also required. EPA publishes Alerts to increase awareness of possible hazards.

The primary issue in the alert was that companies who have processes that rely on the EFV for release control alone might be positioning themselves for sustaining an unnecessary risk. There were three clear issues that need review.

The first is the practice of inherently safer design. When EFV’s are selected for hazardous material service, they need to be designed and installed in a fashion that allows the device to function as intended.

  1. Orientation is critical for ball check design. The EFV must be installed in the vertical orientation and with the device so that the ball moves upward against the seat to stop/restrict flow
  2. Spring loaded, ball check, or other technology designs for EFV devices are installed following a design review of potential of:
    1. Particulate entrainment in the process fluid that would prevent operation
    2. Process conditions that would result in solids formation preventing closure of the device
    3. Vapor/liquid two phase flow conditions that could develop causing
      1. Cavitations and loss of face to face material resulting in material bypass
      2. Brittle fracture engagement if temperatures achieved resulting in mechanical failure
      3. Failure to reach sufficient force to operate the device, and
      4. Other process specific concerns
    4. By-product or contaminants that could result in accelerated or pre-mature failure
    5. Flow restrictions or operating pressures upstream or downstream that may prevent the device from operating as desired (i.e. flexible hoses in unloading systems to determine if the flow resistance in the intervening piping might prevent the EFV from closing)
  3. Design installation so that the device can be maintained and inspected.

The second concern to address is to ensure in existing EFV installations that a proper inspection and maintenance program is employed to ensure reliable service or device, especially when it is needed most. Previous history (not only in-house, but others industry and companies that may lessons to learn from) may provide insight into how and when to service or inspect these devices. The Natural Propane Gas Association (NGPA), the Chlorine Institute (CI), International Institute of Ammonia Refrigeration, American Chemical Council, American Petroleum Institute, and other have sources of information/meetings where issues are addressed and questions answered that will help in identifying maintenance/inspection needs.

The third concern was with careful analysis and additional measures based on the risk related to the release of the material. The company should evaluate the frequency versus consequence if the EFV fails and it was the only layer of protection provided. Several examples are given in the alert that address failure and consequence of real life events that occurred.

The conclusion is that companies relying only on one layer of protection, one device between control and catastrophe, should carefully look at there applications and see if the right measures are in place to prevent the potential for accidents that could cause loss of life, employee exposures, loss of operations, and their community harm.

RCP, Your Regulatory Compliance Partner, has subject matter experts that can assist in evaluations and risk analysis for this and process related concerns for Process Safety Management, Risk Management Programs, Pipeline Integrity Management, and other concerns. For more information contact Dan Shelledy or call (713) 655-8080.

RCP Services Spotlight – Pipeline Integrity Management

RCP has been involved in 28 Pipeline Integrity Management Programs to date including the development of 15 complete programs for both large and small companies or industrial facilities. RCP has experience in Integrity Management Programs for both gas and hazardous liquids pipelines. These services include the following:

  • Plan Development – RCP can start from scratch or use your existing program to complete a comprehensive plan to meet the latest regulations. RCP has a proven Risk Assessment Model to evaluate your pipeline segments and prioritize your future work as part of your Integrity Management Program.
  • Program Audits – RCP will audit your existing Integrity Management Plan using DOT/OPS protocols and make recommendations for improvements or assist you in performing the required plan modifications. Our experts have participated in several DOT audits and can provide you with valuable insight as to how your program will perform under a comprehensive DOT IMP audit.
  • Integrity Management Workshops / Training – RCP holds several DOT Workshops throughout the year which provide excellent training for those who are new to Integrity Management and for experienced pipeline professionals who need to learn the most recent changes in the regulations. We can provide this training on site at your facilities and tailor the program to your specific needs.
  • Mapping Services / HCA Assessments / NPMS Submittals/ Class Location Studies – RCP provides a host of other relates services and special projects related to all aspects of Integrity Management and DOT Pipeline Compliance.

Please Click Here if you would like information on RCP’s Integrity Management Services and receive a copy of our FREE Integrity Management CD which includes a “Bookmarked” PDF file copy of the new Gas Integrity Management Rule and one of our recent conference presentations “ Preparing for a Pipeline Integrity Management Audit – Covering All the Bases”.

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