DOT Pipeline Compliance News

November 2004 Issue

In This Issue

Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines

The DOT has proposed regulations that would require pipeline operators to meet certain standards if they use direct assessment to evaluate the threat of corrosion on regulated onshore gas, hazardous liquid, and carbon dioxide pipelines. The standards, which are already in effect for gas transmission lines in high-consequence areas, involve processes of data collection, indirect inspection, direct examination, and evaluation. The proposed regulations should advance the use of direct assessment as a method of managing the impact of corrosion on regulated pipelines.

Persons interested in submitting written comments on the rules proposed in this document must do so by December 6, 2004 (docket RSPA-04-16855). For a complete copy of the proposed rule, contact Laura Wager at

Operator Qualification Rulemaking Update

The long awaited ASME B31Q standard for operator qualification will not be ready before the deadline to comply with the Pipeline Safety Improvement Act of 2002 requirements. RCP understands that the ASME B31Q committee will meet again in July, 2005. This will likely prompt the OPS to issue a Notice of Proposed Rulemaking that would add the PSIA 2002 requirements to the existing OQ regulations. However, even without new regulations the law will take effect that will require pipeline operators to ensure their OQ Program complies with the following provisions of the PSIA 2002 prior to December 17, 2004:

  1. The method may not be limited to observation of on-the-job performance, except with respect to tasks for which the Secretary has determined that such observation is the best method of examining or testing qualifications. The Secretary shall ensure that the results of any such observations are documented in writing.
  2. A program to provide training, as appropriate, to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operation of pipeline facilities.

If you would like a copy of the PSIA 2002 or would like to discuss how RCP can help update your Operator Qualification Program to meet the PSIA 2002 requirements, please click here.

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.

OPS Issues Draft Stress Corrosion Cracking Study

Stress corrosion cracking (SCC) is a known integrity threat to the safe operation of the nation’s critical pipeline infrastructure. This threat has been studied and examined in the past, but the phenomenon generally is not well understood. As part of its many efforts to foster safe pipeline operations, OPS commissioned a study of SCC issues relating to pipeline integrity for both gas and liquid lines. The SCC study has been designed to synthesize what is already known about the history of SCC, level of risk, indicators of the potential for SCC, detection methods, mitigation measures, assessment procedure, and actions taken by pipeline operators to facilitate response to SCC-related incidents. The study is intended to be comprehensive in scope and provide a common basis for improving avoidance, detection, and management of this integrity threat.

This study was extensively coordinated with pipeline regulators – both U.S. and Canadian, major pipeline industry trade organizations, selected pipeline operators with SCC expertise, and well known technical experts. Known information on the subject of SCC has been assembled or identified, and any gaps in the efforts to understand, identify, assess, manage and mitigate SCC effects and efforts were identified.

This report is still in draft format! A final report will be issued approximately one month after the public comment period.

The full SCC report can be viewed by selecting the following link:

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.

EPA Issues Final NPDES General Permit for New and Existing Sources and New Dischargers in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf of the Gulf of Mexico

Region 6 of the EPA has issued a final National Pollutant Discharge Elimination System general permit for the western portion of the outer continental shelf of the Gulf of Mexico (No. GMG290000). This permit authorizes discharges from new sources, existing sources, and new dischargers in the offshore subcategory of the Oil and Gas Extraction Point Source Category (40CFR part 435, subpart A).

The general permit authorizes discharges in accordance with effluent limitations, monitoring requirements and several other conditions listed in the permit. The requirements cover discharges from exploration, development, and production facilities located in and discharging to Federal waters of the Gulf of Mexico seaward of the outer boundary of the territorial seas offshore of Louisiana and Texas. The Act provides for fines and or imprisonment for negligently or knowingly violating the permit conditions.

The permit will become effective November 8, 2004. This permit reissues an existing permit (published in the Federal Resister 64 FR 19156 and modified in 66 FR 6850) which expired on November 3, 2003.

For further information contact: Ms. Diane Smith, EPA Region 6, 1445 Ross Avenue, Dallas, Texas 75202, Telephone: (214)665-7191, or via e-mail at

Operator Qualification for ILI

In 2001 it was recognized that the existing Operator Qualification (OQ) Rule did not cover performing an ILI or ILI data analysis as “covered tasks”. Both industry and the regulators agreed that the criticality of ILI qualified personnel for Integrity Management is necessary. ASNT agreed to aid in the development of a standard for “ILI personnel” qualification (ASNT ILI-PQ).

The recommended practice will establish the general framework for the qualification and certification of industry specific personnel using nondestructive testing methods in the employment of the ILI tools. The document will provide recommended educational, experience and training requirements for the different type of nondestructive testing methods used by ILI tools. This includes all types of tools that are used to inspect liquid and gas pipelines, such as geometric, magnetic flux, ultrasonic, and electromagnetic acoustic transmission. There are three levels of qualification I, II, III in ascending order of technical and job experience/training for two types of personnel (tool operators and data analysts). Additional information can be found at

O&M Manual Up-To-Date?

RCP has the tools and expertise to develop comprehensive procedures that you need to protect your people, facilities, and environment. Click Here

Public Meetings on Pipeline Safety Issues

The Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) is sponsoring four free public meetings at the Marriott Washington, 1221 22nd Street, NW on the following pipeline safety topics:

  1. Communicating with the Public – Tuesday, December 14 – 1 p.m. to 5 p.m.
  2. Enhancing Integrity Management of Gas Distribution Pipelines – Thursday,
    December 16-8:30 a.m. to 4 p.m.
  3. Updates on Pipeline Drug and Alcohol Program – Thursday, December 16 – 4 p.m. to 5 p.m.
  4. Updates on Operator Qualification Program Implementation and Standards Development – Friday, December 17 – 8:30 a.m. to 12:30 p.m.

These meetings will provide detailed review and discussion on the above topics and will provide the public an opportunity to give comments. Meetings of the pipeline safety advisory committees are scheduled for December 14 and 15. A separate notice has been prepared for those Committee meetings. For further information, contact: Cheryl Whetsel, RSPA/OPS, (202) 366-4431 or Richard Huriaux, RSPA/OPS, (202) 366-4565. Any additional information or changes will be posted on the OPS Web page approximately 15 days before the meeting date 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.

TPSSC and THLPSSC Meetings

Meetings of the Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will be held on December 14 and 15, 2004, at the Marriott Washington, 1221 22nd Street, NW., Washington, DC. Members of the public may attend the meetings, and an opportunity will be provided for the public to make short statements on the topics under discussion. Anyone wishing to make an oral statement should notify Jean Milam, (202) 493-0967, not later than November 16, 2004, on the topic of the statement and the length of the presentation. The presiding officer at each meeting may deny any request to present an oral statement and may limit the time of any presentation. Any additional information or changes will be posted on the OPS Web page approximately 15 days before the meeting date at

The agenda for the THLPSSC meeting on Tuesday, December 14, 2004, from 8:30 a.m. to 12 p.m. est., includes briefings on the following:

  1. American Petroleum Institute (API) Petition-Changes to Liquid Integrity Management Program (IMP).
  2. Response Plans for Onshore Oil Pipelines.
  3. Direct Assessment for Hazardous Liquid Pipelines (scheduled for VOTE).

On Wednesday, December 15, 2004, from 8:30 p.m. to 12 p.m. est., the THLPSSC and the TPSSC will meet in joint session. OPS will provide the committees with briefings on the following:

  1. Common Ground Alliance.
  2. Community and Technical Assistance State Damage Prevention Assessment Briefing.
  3. Pipeline Industry Implementation of Public Awareness Programs (scheduled for VOTE).
  4. Annual Update of Standards Incorporated by Reference (scheduled for VOTE).
  5. Transportation Research Board Report.
  6. Passage of Internal Inspection Devices.

The agenda of the TPSSC meeting on Wednesday, December 15, from 1 p.m. to 5 p.m. est., includes the following topics:

  1. Gas Gathering Line Definition.
  2. Direct Assessment for Gas Pipelines.
  3. Protocols for Gas Integrity Management Program.
  4. Technical Studies by Federal Energy Regulatory Commission and Department of Energy.

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.

Petroleum and Transportation Security

Recent advances in technology have proven to increase the efficiency and control of our pipelines. However, because we have these improvements, there is the flip side to the coin. There are more opportunities for individuals to create hazards for the pipelines and the people associated with their operation. These people include employees, the community, contractors, as well as the environment. The 9/11/2001 attacks on the World Trade Towers, the Pentagon, and the crash of the plane in a field in Pennsylvania has served as a wake up call to the potential harm for our pipelines, refineries, chemical facilities, and our surrounding communities.

A recent article (see the hyperlink included here for a full copy of the article from cano petroleum pipeline magazine – describes a significant connection between motive and opportunity for pipeline attacks in the United States and Canada. Security experts consider pipelines, refineries, barge/vessel material transfer locations, depots, and other oil & gas facilities to be attractive targets to and both industry and government are seeking for solutions. The sixty-four dollar question is – How real is the threat to America’s pipeline industry? This includes not only the field assets, but also the other assets as well – software, SCADA data controls, community relations & trust, the economy.

As recent as Wednesday, November 3, 2004, Al Jezera Television released a video clip communicating how bin Laden seeks to bankrupt America through acts of terrorism. The industry along with a cooperative trade association and a committed Government can formulate how to prevent harm and attack, or minimize the consequence of events by finding innovative solutions. The heart of our ability to operate and grow is through the transportation of goods, especially true is energy resources.

RCP Inc. stands ready to offer probative reviews of your operations and innovative solutions to help your company avoid being the target of choice for terrorists. Don’t forget that the terrorists are not just from overseas. There is the potential for the attack to be a disgruntled individual who knows your organization or an individual who identifies a target by reviewing exposing information on an internet web site about a location or facility (especially those that contain images of key assets). These are just a couple of the items that our subject matter specialists will partner with your organization to harden your defense and provide an opportunity for your continued success. These solutions will include recommendations that will go on into providing for the future that you have worked so hard to contribute positively for years.

For more information on facility security plans for the USCG, DOT transportation security plans for pipeline, trucking and manufacturing facilities, please contact Laura Wager at or by phone at (713) 655-8080 ext 109.

In our July 2004 newsletter, we mentioned that OPS is proposing to incorporate API RP 1162 into the gas and hazardous liquid pipeline regulations. Our Vice President of Project Development, Susan Waller, served on the API committee that developed RP 1162. She would like to add the following comments:

“There is no doubt that everyone in our industry agrees that communication is an important element in helping to assure the safety of our nation’s energy transportation pipeline infrastructure. In addition, it is important for us to recognize that long before RP 1162 was developed, pipeline operators have been communicating with affected stakeholders.

RP 1162 provides operators with a formal process to take credit for and improve their ongoing pipeline awareness communication efforts. Pipeline specific communication takes place routinely during operators’ maintenance programs, emergency responder training, excavator meetings, One-call alliances, incremental pipeline / facilities expansion activities, and day-to-day field personnel interactions with those living and working along the rights-of-way.

What is new for most operators is formalizing their public education programs, documenting targeted communications and evaluating their program’s effectiveness. RP1162 provides operators with a structured and documented process approach that recognizes measurable, ongoing program improvements. If operators plan well, they can minimize their costs and maximize their program’s effectiveness.”


The new rule will set minimum requirements for pipeline operators to develop, implement, and manage public education programs. This will include requirements regarding the stakeholder audiences that pipeline operators should communicate information to, the content of the messages and information they should communicate, and the frequency by which they should communicate with particular audiences. It will also address management of the operators’ programs, including evaluating their programs for effectiveness.

OPS proposes to incorporate RP 1162 by reference into the new rule. OPS worked with industry representatives, state pipeline partners and the National Association of Pipeline Safety Representatives (NAPSR) in developing the new rule. Baseline and supplemental program requirements for different pipeline operator types are summarized in a set of tables in API RP 1162 that may be found at If an operator’s current public education program does not comply with API RP 1162, the operator would be required to modify the program to come into compliance. Information on API RP 1162, may be found at:

Procedural Update – 12/14/04 Public Meeting

OPS will be holding a public meeting on “Communicating with the Public” from 1:00 p.m. to 5:00 p.m. on Tuesday, December 14, 2004 at the Marriot Washington, 1221 22nd Street, NW, Washington, D.C. At the public meeting, OPS will discuss its analysis of comments received in response to the Notice of Proposed Rulemaking (NPRM). Numerous comments to the NPRM raised questions relating to the regulator’s use of language in consensus standards that employ the words “should” and “shall.” OPS will also discuss and solicit comments on its plans to meet statutory responsibility to review communications programs of pipeline operators. The United States Senate Appropriations Committee has proposed a budget increase to fund a central review clearinghouse, but that model is contingent on availability of financial resources. Other models for review of communications plans will also be discussed at the public meeting. If you would like information regarding RCP’s Public Awareness Program development, e-mail Laura Wager at or call (713) 655-8080.

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