The Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet on Monday, August 13, 2001 from 10:00 a.m. to 12:00 p.m. to discuss comments received and vote on Section 195.452(h) of the final rule for Pipeline Integrity Management in High Consequence Areas (Hazardous Liquid Operators With 500 or More Miles of Pipeline), as published on December 1, 2000. The THLPSSC will also discuss and vote on the proposed rule "Pipeline Integrity in High Consequence Areas (Hazardous Liquid Pipelines With 500 Miles or Less of Pipeline)," which was published on March 25, 2001 (66 FR 15821). A copy of the proposed rule can be found on the Internet-OPS Docket Management System http://dms.dot.gov (Docket Number 7408).

The THLPSSC is a statutorily mandated advisory committee that advises RSPA's OPS on proposed safety standards and other safety policies for hazardous liquid pipelines. The committee consists of 15 members-five each representing government, industry, and the public. Members of the public may attend the meeting in person at the Department of Transportation, Nassif Building, Room 7128, 400 Seventh Street, SW, Washington, DC 20590. Due to limited space, anyone wishing to attend or participate should notify Juan Carlos Martinez, at (202) 366-1933, not later than July 30, 2001. FOR FURTHER INFORMATION CONTACT: Cheryl Whetsel, OPS, (202) 366-4431 or Richard Huriaux, OPS, (202) 366-4565.

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.

As compliance deadlines approach for OPS's first integrity management rule (see RCP's December, 2000 newsletter)HERE, OPS is hosting two workshops to promote a better understanding of the new requirements, and to discuss compliance approaches operators are applying to various aspects of the rule. OPS will host additional workshops if needed.

The first workshop will be on August 7-8, 2001, from 8:30 a.m. to 5 p.m., at the DoubleTree Hotel Post Oak, 2001 Post Oak Boulevard, Houston, Texas, 77056, 713-961-9300 or 800-566-5216. Click HERE for the agenda. The second workshop will be on October 10-11, from 8:30 a.m. to 5 p.m., at the Renaissance Houston Hotel, 6 Greenway Plaza East, Houston, Texas, 77046, 713-629-1200 or 800-Hotels-1. No later than September 12, 2001, rooms may be reserved within a block identified as "DOT/IMP Public Meeting Block".

Each workshop will be two days long, and will cover the same topics. On Day 1, OPS will familiarize participants with the new requirements, and present and seek comments on the approach OPS plans to use for achieving compliance. On Day 2, OPS will provide a forum for participants to share and discuss noteworthy integrity management practices that achieve compliance with the rule. Via the presentations, OPS hopes to encourage a peer-to-peer exchange among operators of innovative approaches being developed to enhance pipeline integrity and comply with the rule. Each presentation will be followed by an open discussion among meeting participants. Based on these discussions, OPS will kick-off development of an on-line forum that will enable continued exchanges between federal and state regulators, representatives of public interest and environmental organizations, the pipeline industry, and other interested parties about noteworthy practices.

FOR FURTHER INFORMATION CONTACT: Beth Callsen, tel: 202-366-4572; E-mail: beth.callsen@rspa.dot.gov. For event planning purposes, please let Ms. Callsen know if you will attend. Also notify Ms. Callsen if you are interested in being a presenter on Day 2 of one or both of the workshops (note – DOT is only looking for pipeline operators to make presentations – not consultants).

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) (64 FR 32610). The Oil and Gas NESHAP require new and existing major sources to control emissions of hazardous air pollutants (HAP) to the level reflecting application of the maximum achievable control technology (MACT). On June 28, 2001, EPA issued technical corrections that clarify intent and correct errors in the Oil and Gas NESHAP. These corrections become effective June 29, 2001. These editorial, cross-referencing and clarifying corrections are minor in nature and are noncontroversial. However, they do contain clarifications of jurisdiction that could be important to the gas transmission industry. The corrections document is available on the Technology Transfer Network (TTN) at http://www.epa.gov/ttn/oarpg.

On July 30, 2001, the National Oceanic and Atmospheric Administration (NOAA) proposed amendments to their Natural Resource Damage Assessment rule in 15 CFR 990. The proposal addresses issues from a recent court ruling, and includes some clarifying and technical amendments in other parts of the regulation. This rule will affect companies that are held responsible for natural resource damages for oil and other hazardous substance spills, including liquid pipeline operators and dock operators. The entire notice can be downloaded from RCP's website HERE.

In the event of a discharge or substantial threat of a discharge of oil (incident), the Oil Pollution Act of 1990 (OPA-90), provides that federal, state, Indian tribal, and/or foreign natural resource trustees assess natural resource damages and develop and implement a plan for the restoration, rehabilitation, replacement, or acquisition of the equivalent, of the injured natural resources and their services under their trusteeship. Congress directed the National Oceanic and Atmospheric Administration (NOAA) to promulgate regulations for the assessment of natural resource damages resulting from an incident (OPA section 1006(e)(1)). NOAA promulgated final regulations on January 5, 1996 (see 61 FR 440), codified at 15 CFR Part 990.

Under these OPA regulations, trustees conduct natural resource damage assessments in the open, with responsible parties and the public involved in the planning process to achieve restoration more quickly, decrease transaction costs, and avoid litigation. These restoration plans form the basis of claims for natural resource damages. Under the natural resource damage assessment regulation, trustees then present a demand comprised of the final restoration plan to responsible parties for funding or implementation.

Help Wanted

Know someone with regulatory expertise who is interested in full or part time work? Our recruiting coordinator would be glad to get their resume! Have them sent to chandra@your-rcp.com, or FAX to 713-655-8083.