The Common Ground Alliance was formed as a joint effort between OPS and industry to improve damage prevention for buried pipelines. As part of their work, the CGA conducted extensive research to determine the "best practices" that were being used to minimize damage to buried facilities. The report summarizing these practices is 262 pages long. Don't despair, however. The key information has been distilled into 8 Damage Prevention Best Practices brochures, addressing each functional area of the damage prevention process:
- One Call
- Planning & Design
- Reporting & Evaluation
- Compliance
- Public Education
- Mapping
- Locating & Marking
- Excavation
These brochures have been reviewed and approved by all damage prevention stakeholder groups represented in the CGA. The brochures are packaged individually in bundles of 250 copies, and are available by contacting Revak & Associates by phone: 330-533-1727, or by email: krevak@aol.com. The brochures cost $18 per bundle of 250 + shipping. However, if you require less than 75 copies of any individual brochure, please send an Email message to Bob Kipp (bkipp1@aol.com), the CGA Executive Director, and he will arrange for shipment from the CGA office at the same prorata unit price + shipping. The OPS notice concerning these brochures is located here.
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.
The Advisory Council on Historic Preservation proposed a Program Comment to streamline the historic preservation review process for projects involving historic natural gas pipelines (see our November 2001 newsletter). The original comment period, November 9, 2001, has been extended to December 10, 2001. Address all comments concerning this proposed program comment to Don Klima, Director, Office of Planning and Review, Advisory Council on Historic Preservation, 1100 Pennsylvania Avenue, NW., Suite 809, Washington, DC 20004. Phone (202) 606-8505, Fax (202) 606-8672. You may submit electronic comments to dklima@achp.gov.
New EPA Texas Coastal Water General Discharge Permit
On November 15, 2001, EPA Region 6 today issued a National Pollutant Discharge Elimination System (NPDES) general permit regulating discharges from oil and gas wells in the Coastal Subcategory in Texas and regulating produced water discharges from wells in the Striper and Offshore Subcategories which discharge into coastal waters of Texas. While this permit is primarily of interest to oil and gas production companies, it could also impact DOT jurisdictional pipeline operators in this area.
The permit prohibits the discharge of drilling fluid, drill cuttings, produced sand and well treatment, completion and workover fluids. Produced water discharges are prohibited, except from wells in the Stripper Subcategory located east of the 98th meridian whose produced water comes from the Carrizo/Wilcox, Reklaw or Bartosh formations in Texas. Discharge of dewatering effluent is prohibited, except from reserve pits which have not received drilling fluids and/or drill cuttings since January 15, 1997. The discharge of deck drainage, formation test fluids, sanitary waste, domestic waste and miscellaneous discharges is authorized. All of the authorized discharges have effluent limitations.
The limits and monitoring requirements in this permit are effective on December 17, 2001. The full notice and permit conditions can be obtained on RCP's website at 66 FR 57457 11-15-01 TX Coastal Gen Disch Permit.pdf.
DOT Mail Processing Issues 2000
We picked this up off the DOT's Docket Management System website on 11-6-01. It may still be effective by the time you receive this newsletter, and could be important to you even if it is not:
Currently, the Department of Transportation (DOT) is not receiving United States Postal Service (USPS) deliveries. It is unclear how long this will continue. We wish to advise the public that we will take this into account, with respect to DOT rulemakings documents that have comment periods that may close before mail delivery resumes. We will do everything that we can to ensure that we consider comments that would otherwise have been received before the close of the comment period. (For example, we generally have the authority to consider late-filed comments and will do so to the extent that we can; we will also take note of the date of the postmark for late-filed comments.) For adjudicatory proceedings, filing date requirements remain unchanged.
Although U.S. mail delivery by the USPS is not being accepted, deliveries are accepted from alternate delivery carriers. All package deliveries must be x-rayed and screened by the DOT Mail Room prior to their acceptance in DOT DOCKETS. The Mail Room is located on the plaza level. In addition, where appropriate, filers are encouraged to use the Electronic Submission System on the Dockets web page (dms.dot.gov) by clicking on ES Submit and following the online instructions.
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 mentioned in our September, 2001 newsletter, the DOT is planning to conduct "quick hit" audits of large liquid pipeline operators in early 2002 to ensure that their Pipeline Integrity Management program is on-track. The DOT recently posted their quick hit audit guidelines on the IMP website at http://primis.rspa.dot.gov/iim/protocol.htm. Note that these guidelines may continue to change before the end of this year, but the current guidelines give a very good idea of the types of information they are looking for in a PIM program. Remember that this is a situation where first impressions matter. If your company fares poorly (or below the average of other companies that were audited), you will face an in-depth audit earlier than the rest.
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.
Heather Roark
Jessica Foley
