DOT Pipeline Compliance News

November 2003 Issue

In This Issue

Pipeline Industry Implementation of Effective Public Awareness Programs Self Assessment Now Available

The Office of Pipeline Safety (OPS) has issued an advisory bulletin to owners and operators of regulated hazardous liquid pipelines, gas transmission pipelines, gas distribution pipelines, and crude oil and gas gathering pipeline systems. The Pipeline Safety Improvement Act of 2002 (PSIA) requires that each owner or operator of a gas or hazardous liquid pipeline facility implement a continuing public education program. By December 17, 2003, each owner or operator must review its existing public education program for effectiveness and modify the program as necessary.

RSPA/OPS is asking that each operator complete a self-assessment of its public education program against the guidelines established in the proposed consensus standard, American Petroleum Institute’s API RP 1162, “Public Awareness Programs for Pipeline Operators,” before December 17, 2003, to demonstrate compliance with the PSIA. The assessment form can be completed on-line (recommended) or printed and submitted via U.S. Mail or facsimile. You can access the forms on the OPS website here. API RP 1162 has not yet been officially incorporated into the OPS regulations, and that the modifications to an operator’s public awareness program, if any are required, should be those necessary to meet the existing regulations in 49 CFR Parts 192 and 195.

The full advisory bulletin is available from RCP’s website here through the DOT Gateway.

Additional information can by found at the end of this Newsletter in the “RCP Services Spotlight” where in this issue we discuss RCP’s DOT Pipeline Public Awareness Program. You can go directly to the “RCP Services Spotlight” here.

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.

Electronic Contingency Plans

Ahead of our time…. Companies have recently asked us whether we can assist them with electronic contingency planning. Of course, the answer is yes. In fact, we developed software over 3 years ago that is perfectly suited for electronic contingency plans. We call it “Intellinav”. Using Intellinav, your contingency plan documents can reside on a secure server, and be accessed either over your intranet or the internet. Some of the benefits include:

  • The documents can stay in their original format, and don’t have to be converted to HTML. For example, Word documents can stay in Word. Adobe Acrobat documents can stay in Adobe Acrobat, etc. Updates and revisions are very easy, and can be done by your own staff.
  • One document can be automatically incorporated into many plans. For example, a company phone list can be incorporated into every response plan, without having to copy the document multiple times.
  • Any change to any document is automatically reflected within every plan that uses that document. For example, the company phone list can be modified once, and the new document will be automatically incorporated into every plan.
  • Every plan can be searched by key word, either individually or as a group. Any hits include a short abstract of each document, so it is easy to find the document that you are looking for.

Intellinav uses an interactive document index that lets you “drill down” to several levels of detail within a document. For example, it is very easy to select a specific plan, expand chapter 6 of the plan, then expand subchapter B, then browse to the applicable section. You only see the level of detail that you want, without having to scroll through lots of extraneous information.

We use this software on several of our own websites, and have used it on client projects as well. After all, we’ve done contingency plans for some of the largest facilities in the United States! If you would like a demonstration, please contact Dan Shelledy at

Pipeline Safety: Stress Corrosion Cracking (SCC) Workshop

The Office of Pipeline Safety and the National Association of Pipeline Safety Representatives are cosponsoring a workshop on stress corrosion cracking (SCC) with the pipeline industry trade associations (API, AOPL, INGAA, AGA, and NACE International). The workshop will be held on Tuesday, December 2, 2003, from 8:00 a.m. to 5:00 p.m. at the Westin Oaks Hotel, 5011 Westheimer Blvd., Houston, TX 77056 (telephone: 713-960-8100; fax: 713-960-6553). To facilitate meeting planning, advance registration for this meeting is strongly encouraged and can be accomplished online at the following web site: EDITOR’S NOTE: THERE WAS A TYPO IN THIS LINK IN THE OFFICIAL OPS NOTICE, WHICH PREVENTED IT FROM WORKING. THE LINK IN THIS NOTICE IS CORRECT.

RSPA/OPS recently issued an Advisory Bulletin to remind owners and operators of gas transmission and hazardous liquid pipelines to consider SCC as a risk factor when developing and implementing Integrity Management Plans. All owners and operators of pipeline systems, whether or not their pipeline systems are subject to the Integrity Management Plan rules, should determine whether their pipeline system is susceptible to SCC and assess the impact of SCC on pipeline integrity. Based on this evaluation an operator should prioritize application of internal inspection, hydrostatic testing, or other forms of integrity verification.

The workshop on December 2, 2003, will address the following topics:

  1. Stress Corrosion Cracking – description, science, and history
  2. Practical application of SCC principles – how to assess SCC in operating pipelines within the context of integrity management
  3. Response to the occurrence of SCC – guidelines for response and remediation; addressing public concerns
  4. Research and development – knowledge gaps and next steps

This is a technical workshop aimed at sharing information on SCC in pipelines among operators and technical experts, providing regulators with information they can use in pipeline inspection and oversight, and reviewing priorities for research to address the problems posed by SCC in operating gas and hazardous liquid pipelines.

FOR FURTHER INFORMATION CONTACT: Janice Morgan (telephone: 404-562-3552; E-mail regarding the subject matter of this notice. For a copy of the SCC advisory notice, please contact Dan Shelledy at

O&M Manual Up-To-Date?

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TCEQ Adopts New Requirements for Petroleum Storage Tank Releases

The Texas Commission on Environmental Quality (TCEQ) has adopted new requirements for investigating and reporting of releases from petroleum storage tanks. Releases from underground storage tanks or above-ground storage tanks where the release is reported on or after September 1, 2003, are subject to the Texas Risk Reduction Program (TRRP) rule (30 Texas Administrative Code [TAC] 350). The following is a list of guidance and other sources of information on the regulation of PST sites under TRRP.

New PST Release Determination Guidance

A new guidance on release determination is in the final stages of preparation. The working title is Investigating and Reporting Releases from Petroleum Storage Tanks (RG-411), and the final will be available in September 2003. A preview <> (rough draft) is available now. The purpose of the guidance is to explain the requirements of the TCEQ regarding the investigation and reporting of leaks, spills, and releases from underground and above-ground storage tanks. It will supercede all previously issued guidance related to release determination, and will discuss PST releases in light of the new TRRP requirements, which take effect September 1, 2003.

Comparison of 30 TAC 334 and 30 TAC 350

This guidance document compares the PST and TRRP rules (334 and 350, respectively) and can be downloaded here. It is also available on the TRRP guidance web page, along with the complete list of guidance currently available on application of the TRRP rule.

Determining Which Releases Are Subject to TRRP

A new procedure for determining when releases are subject to TRRP is now available. The procedure applies to all TCEQ Remediation Division program areas including the PST Program, Corrective Action Program, etc. This document will eventually be incorporated into Investigating and Reporting Releases from Petroleum Storage Tanks (RG-411), but is available now as a stand-alone document here. It is also available on the main TRRP web page, along with other information on the TRRP rule. Use of the new TRRP screening process involves (in part) completion of the Tier 1 Ecological Exclusion Checklist (TRRP Figure : 30 TAC §350.77(b)). The Eco Exclusion Checklist can be downloaded in WordPerfect (*.wpd), Acrobat (*.pdf), or Word (*.doc) format.

Application of TRRP to LPST Cases

Information from the TCEQ Remediation Division on Application of TRRP to LPST Cases, which describes some important information on the two programs. For additional information on TRRP, refer to the rule (30 TAC 350), information on the TRRP web page, and guidance documents on the TRRP Guidance and Forms TRRP guidance web page.

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New Texas Oil Spill CD Toolkit (2003)

Editor’s note: the following is excerpted from the MSRC newsletter.

The new Texas Coastal Oil Spill Planning and Response CD Toolkit (2003) will be available at Clean Gulf 2003 in New Orleans. The two biggest changes are to the Area Contingency Plans and to the CD Toolkit’s user interface. Thanks to the hard work of USCG District 8 and OOPS Inc., all ACPs are now in the new One Gulf Plan format and include 6 Geographic Response Plans (MSOs Corpus Christi, Houston/Galveston, Port Arthur, Lake Charles, New Orleans, and Mobile). The CD Toolkit’s user-interface now follows a more logical order. The major categories by which users access information are: ACPs, Maps, RRT VI, Software Applications, Additional Documents, and Internet Links. It is our hope that the reorganization will make navigating the Toolkit a more intuitive process.

Other changes from last year’s Toolkit include:

  1. Replaced the GLO equipment map with the latest version (2003),
  2. Added the new Incident Management Handbook (2001 edition) in English and Spanish,
  3. Added the MEXUS plan,
  4. Added the new “Texas Beach & Access Guide” to marinas and boat ramps,
  5. Replaced the old NOAA ICS forms (pdf) with the latest version (April 2003),
  6. Replaced the PREP Guidelines with the new version (August 2002),
  7. Replaced the Site Safety forms with new “ICS Compatible Site Safety and Health Plan”,
  8. Added 4 new SCAT forms and their respective explanation files, and
  9. Replaced the old NOAA ICS Forms Database with the latest version (April 2003).

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.

National Preparedness for Response Exercise Program (PREP) Schedule

The Coast Guard, the Research and Special Programs Administration, the Environmental Protection Agency and the Minerals Management Service, in concert with representatives from various State governments, industry, environmental interest groups, and the general public, developed the Preparedness for Response Exercise Program (PREP) Guidelines to reflect the consensus agreement of the entire oil spill response community. The National Preparedness for Response Exercise Program (PREP) Guidelines provide guidelines for compliance with the Oil Pollution Act of 1990 (OPA 90) pollution response exercise requirements. The guiding principles for PREP distinguish between internal and external exercises. Internal exercises are conducted within the plan holder’s organization. External exercises extend beyond the plan holder’s organization to involve other members of the response community. External exercises are separated into two categories: (1) Area exercises, and (2) Government-initiated unannounced exercises. These exercises are designed to evaluate the entire response mechanism in a given area to ensure adequate pollution response preparedness. The next triennial schedule of Area exercises has recently been announced. If a company wants to volunteer for an Area exercise, a company representative may call either the Coast Guard or EPA On-Scene Coordinator (OSC) where the exercise is scheduled.

The Government-Led Area Exercises for Calendar Year 2004 are:

  • Guam (Marine Safety Office (MSO) Guam)
  • Los Angeles/Long Beach South (MSO LA/LB)
  • San Diego (MSO San Diego)
  • Prince William Sound (MSO Valdez)

The Industry-Led Area Exercises for Calendar Year 2004 are:

  • Chicago, IL (MSO Chicago)
  • Long Island Sound (MSO Long Island)
  • Maryland Coastal (MSO Baltimore)
  • San Francisco Bay (MSO San Francisco
  • South Texas Coast (MSO Corpus Christi)
  • Charleston, SC (MSO Charleston)
  • Morgan City, LA (MSO Morgan City)
  • New York, NY (Activities NY)
  • Savannah, GA (MSO Savannah)
  • Duluth-Superior (MSO Duluth)
  • Eastern Wisconsin (MSO Milwaukee)
  • Northwest-Puget Sound (MSO Puget Sound)
  • Region IV RCP (EPA Region IV)
  • Region VII RCP (EPA Region VII)

The Preparedness for Response Exercise Program (PREP) Area exercise schedule and exercise design manuals are available on the Internet at To obtain a hard copy of the exercise design manual, contact Ms. Melanie Barber at the Research and Special Programs Administration, Office of Pipeline Safety, at 202-366-4560. The 2003 PREP Guidelines booklet is available at no cost on the Internet at or by writing or faxing the TASC DEPT Warehouse, 33141Q 75th Avenue, Landover, MD 20785, facsimile: 301-386-5394. The stock number of the manual is USCG-X0241. Please indicate the quantity when ordering. Quantities are limited to 10 per order.

If you have questions on this notice, or need general information regarding the PREP Program and the schedule, contact Mr. Robert Pond, Office of Response, Plans and Preparedness Division (G-MOR-2), U.S. Coast Guard Headquarters, telephone 202-267-6603, fax 202-267-4065 or e-mail

API Publishes Pipeline Right-of-Way Awareness Brochure

Petroleum Pipelines in Your Community, a four-color brochure that pipeline operators can use to help to fulfill their right of way awareness responsibilities under API RP 1162, is now available from API. It is in both English and Spanish and a blank address block is incorporated into the design. A generic copy that can be reviewed and reproduced is available without charge at

Note that this “generic” brochure needs to be customized by the operator before mailing. Operators can purchase an editable version in Quark 5. It includes the graphic files and can be edited for text changes and to include a company’s name, logo and phone number. The Quark 5 CD price to API members is $50; non-members pay $100. For more information, contact Bill Hickman at API, Communications, 202-682-8125 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.

Texas Gas Association – Fall Transmission Roundtable

The Texas Gas Association will host their Fall Transmission Roundtable at the Hawthorn Suites at 830 N St Mary’s in San Antonio, November 5-7, 2003. Topics of discussion will include:

  • Regulatory Compliance Update
  • Public Education – API 1162
  • Security
  • Safety
  • State of Texas Pipeline Integrity
  • GIS Systems & Digital Mapping
  • Operations & Maintenance
  • Operator Qualification
  • Pipeline Cleaning/Pigging & Smart Pigging
  • One-Call
  • Measurement and L&U;
  • Contracting and Outsourcing

The room rate will be $99. For further information or to register, please visit or contact Shoshanna Solomon at 972.926.8318 or

Direct Assessment Meeting

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 with the pipeline industry trade associations (API, Interstate Natural Gas Association of America, Association of Oil Pipelines, American Gas Association, National Association of Corrosion Engineers (NACE), and American Public Gas Association) on November 4, 2003 at the Wyndham Greenspoint North Hotel, 12400 Greenspoint Dr, Houston, TX 77060 to discuss direct assessment technology. The workshop is intended to provide a forum for the discussion of direct assessment technology as it relates to natural gas integrity management. The RSPA/OPS will gather issues presented at the workshop needing additional clarification or guidance material development. The purpose of the workshop is to:

  • identify issues with direct assessment that need clarification or additional guidance material development;
  • familiarize operators with the current status of direct assessment research and development;
  • provide examples of implemented direct assessment programs; and
  • familiarize operators with the current status of development of NACE direct assessment standards for External Corrosion, Internal Corrosion, and Stress Corrosion Cracking.

Use the following link to register for the OPS meeting:;=19.

Note also that OPS intends to do a web-cast of this meeting. Use the same link above to participate in the webcast.

Note that NACE International will also have a Direct Assessment workshop in the same hotel on Nov. 5-7. For additional information on the NACE meeting, click here:

National Forest Service Interim Direction for Processing Interstate Natural Gas Pipeline Proposals

The Forest Service has issued an interim directive to guide its employees in processing proposals for interstate natural gas pipeline projects. This interim directive is designed to supplement existing direction in the Forest Service Manual chapter 2720, consistent with a May 2002 interagency agreement between the Department of Agriculture and the Federal Energy Regulatory Commission. The agreement establishes procedures for responding to and processing applications for interstate natural gas pipeline projects when the Federal Energy Regulatory Commission will be the lead agency in conducting the required environmental and historic preservation reviews.

The May 2002 agreement entitled “Interagency Agreement on Early Coordination of Required Environmental and Historic Preservation Reviews Conducted in Conjunction with the Issuance of Authorizations to Construct and Operate Interstate Natural Gas Pipelines Certificated by the Federal Energy Regulatory Commission” eliminates overlapping and duplicative environmental processes required by the numerous Federal agencies having jurisdiction in the permitting of interstate natural gas pipeline projects. Minimizing the duplication and overlap of procedures shortens the cumulative processing time for evaluating applications and making decisions on these projects. The ID to FSM 2720 provides Forest Service field officers with specific procedures to ensure that the agency carries out the streamlining processes in the agreement and directs that field officers fully engage as a cooperating agency in the FERC’s processing of these types of applications.

This interim directive (ID 2720-2003-2) is effective October 24, 2003, and is available electronically from the Forest Service via the World Wide Web/Internet at Single paper copies of the ID are also available by contacting Melissa Hearst, Lands Staff (Mail Stop 1124), Forest Service, 1400 Independence Avenue, SW., Washington, DC 20250-1124 (telephone 202-205-1196).

RSPA Administrator Presentation

Samuel G. Bonasso’s presentation at the Senate Committee on Commerce, Science, and Transportation on October 9, 2003 is available at This presentation gives an excellent overview of the history of the Office of Pipeline Safety, their recent activities, and areas of emphasis.

Partnership for Excellence in Pipeline Safety

The National Association of State Fire Marshals (NASFM) has partnered with the Office of Pipeline Safety to help ensure the safety of America’s vast and growing pipeline infrastructure. The resulting Partnership for Excellence in Pipeline Safety has set a goal of zero pipeline incidents. The Partnership will go beyond the traditional agencies and organizations engaged in pipeline safety. NASFM will rely on the experience and lessons learned from the many existing pipeline safety programs, from federal, state and local regulators involved with pipeline safety, from industries that use and operate pipelines, and from communities with pipelines in their backyards. Ultimately, the program will not focus on simply doing what is required, but on achieving a level of excellence that far exceeds minimum safety standards. The partnership’s website is located at:

Gathering Line Definition: Public Meeting and Request for Comments

OPS has announced a public meeting and an opportunity to submit written comments on the safety regulation of gas and hazardous liquid gathering lines. Congress has directed RSPA to define “gathering line” for gas and hazardous liquid pipeline transportation and, if appropriate, define as “regulated gathering line” those rural gathering lines that, because of specific physical characteristics, should be regulated. The gas pipeline regulations do not clearly distinguish gathering lines from production facilities and transmission lines. This lack of clarity has caused many disputes between government and industry over whether the regulations cover particular pipelines. OPS will consider all public comments in developing future proposals on gathering lines.

The public meeting will occur Wednesday, November 19, 2003, from 1:00 pm to 5:00 pm, and Thursday, November 20, 2003, from 8:00 am to 5:00 pm at the Omni Austin Hotel, 700 San Jacinto Blvd, Austin, TX, 78701 (phone: 512-476-3700). If you want to make an oral presentation, please notify Janice Morgan by November 14, 2003, by phone (202-366-2392 ) or by e-mail (, and state the approximate length of your presentation. In addition, you may submit written comments to the docket by December 19, 2003 (docket No. RSPA-98-4868).

OPS is especially interested in receiving comments on the following:

  1. The point where gas production ends and gas gathering begins.
  2. The point where gas gathering ends and gas transmission or distribution begins.
  3. In defining “regulated gathering line,” whether we should consider factors besides those that Congress specified (see footnote 2). For example, should we consider population density (by census or house count), or for hazardous liquid lines, potential for environmental damage.
  4. Whether Part 195 should apply to rural gathering lines that operate at more than 20 percent of specified minimum yield strength, or that could adversely affect an “unusually sensitive area” as defined in § 195.6. (Note that certain crude oil gathering lines are, by law, exempt from safety regulation (see footnote 2)).
  5. If you recommend safety regulations for rural gas or hazardous liquid gathering lines, to which rural lines would the regulations apply and why, approximately how many miles would be covered by the regulations, and what would be the estimated cost per mile of complying with the regulations.
  6. The approximate mileage of rural gathering lines not now covered by Part 195.
  7. Whether safety regulations for gas or hazardous liquid rural gathering lines operating at low stress (e.g., 20 percent or less of specified minimum yield strength) or a specified pressure for plastic lines should be fewer and possibly less stringent than regulations for other rural gathering lines.

There will be an open session for questions and answers before the close of the meeting. Additional meetings are being planned, and dates and places will be announced in future notices.

RCP Services Spotlight – DOT Pipeline Public Awareness Programs

RCP’s Pipeline Public Awareness Program clients include several pipeline companies throughout the US, from local distribution systems to a major natural gas transmission company with over 10,000 miles of pipeline spanning the US from the Gulf Coast to the Midwest, Northeast and Canada. Our services include:

  • Development of a comprehensive written Public Awareness Program utilizing the 12 elements outlined in the API RP 1162 (Draft September 2, 2003).
  • Completion of the self-assessment forms to be submitted to DOT by December 17, 2003.
  • Provide implementation support including audience identification analysis, develop messages tailored for each audience type, create mail-piece, postage delivery, provide audit documentation, post mailing response analysis, ongoing program improvement and maintenance.

Please Click Here if you would like information on RCP’s Public Awareness Program services.

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