The National Transportation Safety Board conducted a Pipeline Safety Hearing on November 15 and 16, 2000, in Washington, D.C. The Pipeline Safety Hearing provided a forum to examine technologies available to assess the integrity of pipelines, such as the use of internal inspection tools, and the capability of pipeline operating systems to identify leaks and to prompt timely responses. The hearing also determined the status of ongoing research in these areas. The minutes and presentations from this meeting are available at http://www.ntsb.gov/Events/2000/pipeline_hearing/agenda.htm. An especially interesting set of slides, with pictures of the pipe from numerous pipeline failures is contained in the presentation at http://www.ntsb.gov/Events/2000/pipeline_hearing/Dyck_Rod.htm.

In his opening comments, Chairman Jim Hall stated: "As I mentioned earlier, RSPA's Office of Pipeline Safety has begun to take action that will strengthen the Nation's pipeline safety requirements, and I want to urge the industry to support RSPA's efforts to establish national pipeline inspection and testing standards." He also stated: "Just last week, RSPA issued a final rule to require pipeline operators, who operate 500 or more miles of hazardous liquid pipeline, to establish an integrity management program for high-consequence areas. According to RSPA, this rule will cover 87 percent of all hazardous liquid pipelines. We will be examining this final rule closely. But, it appears to be the first step to ensuring that pipelines are properly inspected and tested." Note the description of the latest rulemaking as a "first step". Pipeline operating companies can expect more rulemakings to follow….

On December 1, 2000, DOT / OPS issued their final rule on Pipeline Integrity Management in High Consequence Areas for large liquid operators (docket 6355). Note that the final rule as published in the federal register is not identical to the "final" rule that was posted on the OPS website earlier in November! Interested persons are invited to submit comment on the provisions of the rule concerning actions an operator must take to address integrity issues on the pipeline (§195.452(h)) by March 31, 2001 . At the end of the comment period, OPS will publish a document modifying these remedial action provisions or a document stating that the provisions will remain unchanged.

RCP has created a document with diagrams that summarize the requirements of this regulation. Our summary and the actual regulation can be downloaded from RCP's website at http://www.your-rcp.com/downloads/Misc/Dec2000/PIM-HCASummary.PDF The actual regulation can be downloaded at http://www.your-rcp.com/downloads/Misc/Dec2000/65_FR_75378 _PIM_HCA_final_rule_120100.pdf. This final rule specifies regulations to assess, evaluate, repair and validate through comprehensive analysis the integrity of hazardous liquid pipeline segments that, in the event of a leak or failure, could affect populated areas, areas unusually sensitive to environmental damage and commercially navigable waterways. OPS is requiring that an operator develop and follow an integrity management program that provides for continually assessing the integrity of all pipeline segments that could affect these high consequence areas, through internal inspection, pressure testing, or other equally effective assessment means. The program must also provide for periodically evaluating the pipeline segments through comprehensive information analysis, remediating potential problems found through the assessment and evaluation, and ensuring additional protection to the segments and the high consequence areas through preventive and mitigative measures.

Through this required program, hazardous liquid operators will comprehensively evaluate the entire range of threats to each pipeline segment's integrity by analyzing all available information about the pipeline segment and consequences of a failure on a high consequence area. This includes analyzing information on the potential for damage due to excavation; data gathered through the required integrity assessment; results of other inspections, tests, surveillance and patrols required by the pipeline safety regulations, including corrosion control monitoring and cathodic protection surveys; and information about how a failure could affect the high consequence area.

The final rule requires an operator to take prompt action to address the integrity issues raised by the assessment and analysis. This means an operator must evaluate all defects and repair those could reduce a pipeline's integrity. An operator must develop a schedule that prioritizes the defects for evaluation and repair, including time frames for promptly reviewing and analyzing the integrity assessment results and completing the repairs. An operator must also provide additional protection for these pipeline segments through other remedial actions, and preventive and mitigative measures.

This final rule takes effect March 31, 2001. An operator must complete an identification of all pipeline segments that could affect a high consequence area no later than December 31, 2001. An operator must develop a written integrity management program no later than March 31, 2002.

RCP is proud to announce that Mr. Jim Thomas is now associated with the firm. Mr. Thomas worked over 20 years as a senior manager with the Office of Pipeline Safety, including Deputy Director of the national pipeline program and Director of the Southern and Southwest Regions. He was the first pipeline instructor for the Transportation Safety Institute and established the foundation of the DOT pipeline training program. In private industry, he was a Senior Engineer and Storage Field Supervisor with Consumers Power Company. He is a past president of the National Conference of Regulatory Utility Commission Engineers, and has served on the ASME Transportation Committee. He has lectured extensively on pipeline safety issues, and has authored articles for the Journal of Petroleum Technology, Pipeline Industry, and Gas Digest. Please join us in welcoming Mr. Thomas to our growing staff of pipline safety professionals.

The State of Texas proposed a new rulemaking in the November 24, 2000 Texas Register to require pipeline integrity management programs for both liquid and gas intrastate pipelines. The proposed rule is summarized below. The full text of the proposed rule can be downloaded from RCP's website at http://www.your-rcp.com/downloads/Misc/Dec2000/TXPLIntegrityProposedRule11-24-2000TXReg.pdf.

By February 1, 2002, each transmission and jurisdictional gathering operator shall develop, submit to the TRRC, and maintain a pipeline integrity assessment and management plan. The plan may be developed by using risk based analysis or following the prescriptive requirements in the rule. Within 185 days of submittal, the Commission will notify the operator of the acceptance of the plan or complete an evaluation to review compliance with the rule.

Operators chosing to use the Risk-Based Analysis must conduct at least 50% of their initial assessments of integrity by January 1, 2006 and the remainder by January 1, 2011. The assessment plan is required to contain, at a minimum:

1. Identification of the pipelines covered by the plan;
2. Prioritization of pipeline segments based on an analytical process of assessing risks
3. Assessment of pipeline integrity utilizing in-line inspection; pressure test; direct assessment; or other new technology.
4. Management of the pipeline segments which may include remediation or increased inspections as necessary.
5. Periodic review of the pipeline integrity assessment and management plan every 36 months, or more frequently if necessary.

Operators chosing to use the Prescriptive Rule Minimums must pressure test or conduct in-line inspection of each pipeline segment at 5 or 10 year intervals, depending on the location of the pipeline and its service.

In either case, an operator may use an integrity assessment method conducted prior to the effective date of the rule as the assessment if the method meets the requirements of this section.

On November 3, 2000, President Clinton issued an executive memorandum on pipeline safety to the Secretary of Transportation. The memo notes the importance of pipeline safety and mentions improvements that have been made. It also stresses the need for stronger pipeline safety legislation to address five basic principles:

1. improve pipeline safety standards,
2. strengthen enforcement of pipeline safety laws and regulations,
3. enhance Federal-State partnerships,
4. provide the public with better information and opportunities to participate, and
5. support research and development of innovative pipeline safety technologies.

Pending this stronger legislation, the administration is prepared to take action to fulfill these principles to the greatest extent possible using existing authorities. This includes:

• issuing a final rulemaking within 30 days to define environmentally sensitive areas in which hazardous liquid pipeline operators must develop and follow integrity management plans.
• developing and begin implementing no later than January 15, 2001, a comprehensive plan for further improving hazardous liquid and natural gas pipeline safety standards for all hazardous liquid pipeline operators and natural gas transmission pipeline operators.
• prompt proposal of regulations for adequate corrosion control of hazardous liquid and natural gas pipelines, including cathodic protection.
• ensuring that integrity management programs and operator qualification programs are thoroughly reviewed by the Department. These reviews should examine whether operators are using internal inspection, leak detection, and emergency flow restricting devices, where necessary, as a part of their integrity management programs.
• Strengthen enforcement of pipeline safety laws and regulations, and assess the efficacy and current use of all enforcement tools available to the Office of Pipeline Safety.
• Enhance Federal-State partnerships, and issue guidelines, within 60 days, outlining opportunities and responsibilities for States to participate in the oversight of interstate pipelines. Under these guidelines, States should be allowed to participate in new construction and incident investigation, as well as additional oversight of interstate pipeline transportation that will add to overall pipeline safety and address local concerns. In addition, under these agreements, States should be allowed to participate in the review of integrity management, operator qualification, and damage prevention programs.
• Provide the public with better information and opportunities to participate. Develop a comprehensive plan that expands public participation in pipeline decisions and provides increased access to gas and hazardous liquid pipeline data and information including safety-related condition reports, pipeline incident reports, integrity management programs, and operator qualification programs, including access through the internet, annual reports, and other methods as appropriate;
• Collection of more complete and detailed information on the causes of accidents, thereby facilitating better trends analysis and helping to prevent future accidents. Specifically, you should improve accident reporting forms as soon as possible for both hazardous liquid and natural gas pipelines by expanding causal categories and clarifying instructions so that data submissions are more consistent and accurate; and
• assistance to communities to help them more effectively address their pipeline safety concerns, including the potential availability of a limited number of technical assistance grants, subject to the availability of appropriations.
• Supporting research and development of innovative pipeline safety technologies, including expand internal inspection device capabilities to identify and measure defects and anomalies, including automated internal pipeline inspection sensor systems; inspect pipelines that cannot accommodate internal inspection devices, including structural integrity measurement; develop and improve technologies to identify, monitor, and prevent outside force damage, including satellite surveillance; improve corrosion control and prevention methods; expand leak detection; and ensure public safety and environmental protection in other related ways.

The complete memorandum can be downloaded from RCP's website at http://www.your-rcp.com/downloads/Misc/Dec2000/11-3-00ExecutiveMemorandumonPipelineSafety.PDF.

Notice of Second Interstate Natural Gas Facility-Planning Seminar The Federal Energy Regulatory Commission Office of Energy Projects will hold the second in a series of public meetings around the country for the purposes of exploring and enhancing strategies for constructive public participation in the earliest stages of natural gas facility planning. This meeting will be held in Romeoville, Illinois on Thursday, December 7, 2000. We are inviting interstate natural gas companies; Federal, state and local agencies; landowners and non-governmental organizations with an interest in developing a new way of doing business to join us in this effort. We will discuss the facility planning process, not the merits of any pending or planned pipeline projects.

The meeting will be held at the Santa Alberta Convocation Center at Lewis University, located in Romeoville, Illinois. The meeting is scheduled to start at 10:00 AM and finish at 4:00 PM. If you plan to attend, please respond by November 22, 2000 via facsimile to Pennie Lewis-Partee at 202-208-0353, or you can email to: gasoutreach@ferc.fed.us. Please include in the response the names, addresses, and telephone numbers of all attendees from your organization. They will send acknowledgment of your request.

The Sunset Advisory Commission just released a report concerning the Texas Railroad Commission. The 10-member Commission is a legislative body that reviews the policies and programs of more than 150 Texas agencies every 12 years. The section concerning oversight of pipeline safety is entitled "State Regulation of Pipelines Does Not Adequately Protect the Public". Key recommendations from the report include:

• Require the Commission to develop a framework to guide decisions on bringing pipelines outside of its jurisdiction under regulation.
• Authorize the Commission to require a pipeline operator to submit an assessment or testing plan for Commission approval.
• The Commission should create an enforcement coordinating function within the Pipeline Safety Section.

Key findings include:

• The Commission does not have a consistent process for gathering information on pipeline system integrity and using special investigations to help bring pipelines, which may have safety risks, under jurisdiction.
• The Commission does not have a consistent structure to use administrative penalties for the enforcement of pipeline safety regulations.
• Other state agencies have developed processes to ensure compliance and enforcement consistency.

The report concludes:

The Railroad Commission does not have a clear process for determining which pipelines outside its scope of jurisdiction need safety regulation. As a result, the Commission may not be in a position to assess risk of all pipelines to determine where additional regulatory oversight is necessary. These recommendations would establish a framework for the Commission to determine if a pipeline should be under its regulations and if action is needed to avoid pipeline mishaps. The recommendations would also standardize the Commission ’s process for taking administrative enforcement action against pipeline operators by assessing administrative penalties. With these changes, the Commission would be in a better position to know about the risks associated with all pipelines in the state and to take needed action to reduce those risks.

The entire report can be downloaded from the Sunset Commission website at http://www.sunset.state.tx.us (Warning – the file is 1 M in size). The section that just concerns pipeline regulation can be downloaded from the RCP website at http://www.your-rcp.com/downloads/Misc/Dec2000/11-2000SunsetCommissionReport.pdf.

RSPA has entered into a cooperative agreement with the Gas Research Institute (GRI) to co-fund a two year research program to identify and characterizing mechanical damage, the leading cause of reportable accidents in both gas and hazardous liquid pipelines, using the technology of magnetic flux leakage (MFL) oriented in the circumferential direction on an in-line inspection tool. RSPA along with GRI invite the pipeline industry, in-line inspection ("smart pig") vendors, and the general public to a quarterly performance review meeting hosted by RSPA to report on progress with the research "Better Understanding of Mechanical Damage in Pipelines." The quarterly review meeting will be held in room 6244 of the Department of Transportation Headquarters Building, 400 7th Street, SW., Washington, DC. on Thursday, December 7, 2000 beginning at 9 a.m. and ending around 1 p.m. The meeting is open to anyone, and no registration is required.

The meeting will cover a review of the overall project plan, the status of the contract tasks, progress made during the past quarter, and projected activity for the next quarter. FOR FURTHER INFORMATION CONTACT: Lloyd W. Ulrich, Agreement Officer's Technical Representative, Office of Pipeline Safety, telephone: (202) 366-4556, FAX: (202) 366-4566, e-mail: lloyd.ulrich@rspa.dot.gov. You may also contact Harvey Haines, Principal Investigator, GRI, telephone: (773) 399-8223, FAX: (773) 864-3495, e-mail: harvey.haines@gastechnology.org.

Pending Audits?