DOT Pipeline Compliance News

September 2005 Issue

In This Issue

Countermeasures to Prevent Human Fatigue in the Control Room

The Pipeline and Hazardous Materials Safety Administration (PHMSA) urges operators to evaluate potential risks associated with pipeline operator fatigue and shift rotation schedules and take measures to alleviate such risks. PHMSA has issued an advisory bulletin (ADB-05-06) help operators ensure that controllers are not assigned to shift duties while fatigued, to advise pipeline operators on considerations that could cause a reduction of mental alertness or decision-making ability, and to encourage safe management practices. This advisory also responds to the National Transportation Safety Board’s (NTSB) Safety Recommendation P-98-30, which urges PHMSA to establish industry guidelines for pipeline controller work schedules to reduce the likelihood of accidents attributable to controller fatigue. The advisory is available on OPS’s website at:

Several studies are electronically available that provide more information about operator fatigue, such as the U.S. Department of Transportation’s Commercial Transportation Operator Fatigue Management Reference (2003), available at: This publication also references many other studies and reports on human fatigue.

Integrity Management Services

RCP can assist pipeline operators with ongoing compliance management and engineering associated with your IMP. This includes direct assessment strategies, tool and vendor selection, ILI/ECDA report analysis, corrosion control programs, repair strategies, and IMP/risk model updates. For more information on how RCP can support your ongoing IMP needs, Click Here.

Public Meeting on Integrity Management of Gas Distribution Pipelines

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is sponsoring a public meeting on Enhancing Integrity Management of Gas Distribution Pipelines. The meeting will be held on Wednesday, Sept. 21, 2005, from 8 a.m. to 4:15 p.m. at the Westin Park Central Hotel, 12720 Merit Drive, Dallas, TX 75251 (1-972-851-2037 or 1-800-Westin1). At the meeting, PHMSA will discuss actions that have been underway this year to review the need for integrity management requirements for gas distribution pipelines. The meeting also will provide discussion on the use of Excess Flow Valves in gas distribution safety lines as a technique for mitigating the consequences of service line incidents, and will provide the public an opportunity to give comments.

The preliminary agenda for this meeting includes briefings on the following topics:

  • The need for improvement
  • Distinctions among gas distribution pipeline systems
  • Comments from the team of executives (industry, state regulators, and public) providing oversight of the Phase 1 program
  • The plan and process of the Phase 1 program; (including use of EFV as a technique for mitigating the consequences of service line incidents
  • Major issues and approaches, including preliminary Phase 1 conclusions
  • Issues and cautions that must be considered in developing distribution integrity management requirements
  • The views of industry and other stakeholders

The analyses and evaluations conducted by the work/study groups comprise Phase 1 of the PHMSA plan to develop integrity management requirements. Phase 1 is expected to be completed by the end of 2005. The Phase 1 results will support PHMSA and state regulators in making decisions regarding the nature of requirements that may be needed. Achieving increased integrity of distribution pipeline systems may involve Federal and/or State rulemaking, development of guidance for adoption by States, publication and promotion of best practices or national consensus standards, or some combination of these or other actions. PHMSA will use the results of Phase 1 to develop new requirements as part of Phase 2 of the PHMSA plan, which PHMSA expects to begin in early 2006.

Interested parties may find additional information regarding the previous public meeting in the docket (, then click Simple Search and type in Docket No. 19854. Visitors may access the Distribution Integrity Management Web site through the OPS home page ( by selecting Integrity Management and then Distribution Integrity Management.

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.

Changes to OCS Plan and Submittal Requirements

The Minerals Management Service (MMS) has reorganized and updated the requirements and processes for submitting various plans and information for MMS review and approval before a lessee or an operator may explore, develop, or produce oil and gas and sulphur in the Outer Continental Shelf (OCS). The current regulations at 30 CFR part 250, subpart B, were structured into five broad sections: General Requirements, Preliminary Activities, Well Location and Spacing, Exploration Plan, and Development and Production Plan. This new rule reorganizes and clarifies the requirements pertaining to Exploration Plans (EP), Development and Production Plans (DPP), and Development Operations Coordination Documents (DOCD). It also adds sections to describe Deepwater Operations Plans (DWOP) and Conservation Information Documents (CID). The rule provides more descriptive headings under which a large number of separate sections state the current requirements clearly and concisely and in a more logical order to:

  1. Clarify and update the review process
  2. Provide a concise list of the contents of EP, DPP, and DOCD (plan) submissions
  3. Detail the accompanying information that lessees and operators must submit to support their plans

MMS is also issuing a companion Notice to Lessees and Operators (NTL) for the Gulf of Mexico OCS Region (GOMR). This NTL further interprets the requirements in the rule regarding the information a lessee or operator must submit for MMS determinations, analyses, and approvals of EPs and DOCDs as they would apply specifically to leases and units in the GOMR. It also explains how the GOMR is invoking 30 CFR 250.201(c) with respect to limiting submission of information that is not needed in particular cases.

This rule becomes effective September 29, 2005. For a full copy of the new rule, contact Jessica Roger with RCP

RCP Services Spotlight – RCP Auditing, Due Diligence and Expert Witness Services

RCP’s approach to audits and assessments is typically either consultative or enforcement oriented depending upon the client’s needs. The consultative approach is typically viewed by clients as a cooperative effort that assesses regulatory compliance status in concert with operational and maintenance issues. This method provides feedback on existing management practices versus industry standards.

The consultative approach not only identifies opportunities for regulatory compliance improvement, but also provides recommendations on how existing management practices can effectively achieve and sustain these improvements. An enforcement approach gives the client an idea of how well a facility can manage an agency audit and how likely it would be for an agency inspector to issue a Notice of Violation.

RCP provides comprehensive, confidential regulatory consulting services, including:

  • Quick-Hit Regulatory Compliance Checkups
  • Comprehensive Regulatory Compliance Audits
    • Compliance program gap analysis
    • Recordkeeping evaluation
    • Field inspections
  • Regulatory Agency Jurisdictional Determinations, Interpretations & Audits
    • DOT
      • Integrity Management Program
      • Operator Qualification
      • Operations & Maintenance
      • Public Awareness API RP1162
      • Facility Response Plans
    • U.S. Coast Guard
      • Dock Operations
      • Oil Spill Response Plans
      • Facility Security Plans
    • EPA
      • Spill Prevention Control & Countermeasure Plans
      • Air/Wastewater Permitting
      • Facility Response Plans
      • Risk Management Plans
    • OSHA
      • Process Safety Management
      • Health & Safety Plans
    • State-Specific Regulations
  • Asset Acquisition Due Diligence
    • Phase 1 Environment Assessments
    • Permitting & Associated Agency Notifications
    • Compliance Program Development
    • Employee Qualification & Training Program Assessment
    • Asset Integrity Management Liability Assessment
    • Record Keeping, Documentation & Data Room Inspections
  • Expert Witness Service
    • Pipeline Safety
    • Regulatory Interpretation

If you would like information regarding RCP’s Auditing, Due Diligence and Expert Witness Services, e-mail Jessica Roger or call (713) 655-8080.

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

Advisory Bulletin on Pilot Operated Pressure Relief Valve Testing

The Office of Pipeline Safety has issued the following Advisory Bulletin to operators of hazardous liquid pipelines with pilot-operated pressure relief valves:

Advisory Bulletin (ADB-05-05)

OPS shares NTSB’s concern that pipeline operators could be conducting in-service tests that do not identify unreliable pilot-operated pressure relief valves. Therefore, we are issuing the following advisory bulletin:

To: Operators of hazardous liquid pipelines regulated by 49 CFR part 195.

Subject: Inspecting and testing pilot-operated pressure relief valves.

Purpose: To assure that pilot-operated pressure relief valves function properly.

Advisory: Operators should review their in-service inspection and test procedures used on new, replaced, or relocated pilot-operated pressure relief valves and during the periodic inspection and testing of these valves. Operators can use the guidance stated below to ensure the procedures approximate actual operations and are adequate to determine if the valves functions properly.

Guidance: The procedures should provide for the following:

  1. During installation, review the valve purchase order (or comparable documentation) valve name-plate, and manufacturer’s specifications. Verify that the valve is:
    1. Compatible with the material and maximum operating pressure of the pipeline;
    2. Compatible with or protected from environmental attack or damage;
    3. Compatible with the liquid transported at all anticipated operating temperatures and pressures;
    4. In conformity with the manufacturer’s specifications for the valve model and type of service, and with the purchase order (or comparable documentation);
    5. Configured according to the manufacturer’s specifications for the pilot and in-line valves; and
    6. Operable at the set pressure (i.e., activation of the pilot valve opens the in-line valve).
  2. If the pilot assembly of a previously installed valve is reconfigured or repaired
    1. Do the work according to the manufacturer’s specifications;
    2. Test the valve to ensure it is operable at the set pressure (i.e., activation of the pilot valve opens the in-line valve) or, if testing the in-line valve would be unsafe or environmentally hazardous, tests the pilot valve according to paragraph (d) below; and
    3. Document the work.
  3. Verify that the valve set pressure is consistent with
    1. The design or configuration of the pilot valve and in-line valve; and
    2. Use of the valve as a primary overpressure protection device or as a backup safety relief device.
  4. Test the pilot valve at least twice and verify that it activates consistently at the intended set pressure.
  5. During periodic inspections and tests, review the valve installation to determine if it has been modified since the last inspection. If so, verify that the pilot sensor and valve inlet and discharge piping are properly sized and placed and that the installation is consistent with the intended design.
  6. Document all verifications, and sign, date, and keep for the operating life of the valve all documentation.

    The full text of the Advisory Bulletin, with background information, is available on OPS’s website.

Need to Update Your Current Operator Qualification Program?

We have the expertise to update your current operator qualification program to satisfy the upcoming regulation change and inspection protocols. Click Here to request more information.

OPS Meeting on ILI Practices – Presentation Materials

The presentations from the August 11 OPS meeting in Houston on ILI Practices are now available on OPS’s website at: The site contains 19 presentations addressing the various aspects of ILI inspection planning, data interpretation and validation, and industry standards.

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.

Pipeline Safety Trust Newsletter – #2

The second edition of the Pipeline Safety Trust’s newsletter is now available at: The Pipeline Safety Trust promotes fuel transportation safety through education and advocacy, by increasing access to information, and by building partnerships with residents, safety advocates, government, and industry, that result in safer communities and a healthier environment.

This newsletter contains more than a dozen articles concerning pipeline safety from a wide variety of perspectives. A disclaimer in the newsletter states: Some of the articles in this newsletter are attributed to other authors. The opinions and facts presented in those articles are those of the authors, and not of the Pipeline Safety Trust. We may agree with them, we may not, but we do think it is important that all legitimate views on pipeline safety are known and discussed.

Editor’s note: As the disclaimer says: we may agree with them, we may not. But if you deal with the public on pipeline safety issues, it is well worth the time to review the articles in this newsletter to obtain a better understanding of the perspectives and concerns that some members of the public have about pipeline safety.

Pipeline Associations Write to Senate on Pipeline Security (Courtesy of Ben Cooper, Association of Oil Pipe Lines)

AOPL, API, the American Gas Association, and the American Public Gas Association sent a joint letter of views to the Senate Commerce and Transportation Committee this week on a pending bill to reauthorize the authority for the Department of Homeland Security’s Transportation Safety Administration (TSA). The bill, S. 1052, the Transportation Security Improvement Act of 2005, provides Congressional guidance on the various oversight programs of the TSA, including pipeline security. The joint association letter expresses support for TSA to have a lead function in the area of intelligence gathering, assessment and policy and that the Administration leverage the expertise of the Department of Transportation’s Office of Pipeline Safety in the development of any specific regulations deemed necessary. We understand the Committee may hold hearings this fall to gather more information and obtain additional input on recommendations to strengthen the security oversight of all transportation modes, including pipelines. There is currently no companion legislation in the House of Representatives. We will continue to track the development of this issue and keep you posted. The joint letter may be found at

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