This final rule requires gas pipeline operators to further investigate findings of harmful external corrosion on buried metallic pipelines that have been exposed. The investigation should determine if additional harmful corrosion exists in the vicinity of the original exposure and can help determine the significance of initial corrosion discovery. This new requirement may prevent accidents due to corrosion that might otherwise go undetected near an exposed portion of pipeline.
This final rule becomes effective November 22, 1999.
The final rule can be viewed on the RCP Website by clicking here.
How does Y2K affect pipeline safety compliance?
Companies are responsible for addressing potentially adverse conditions on their pipelines. The pipeline safety regulations require procedures to assure safety for adverse, abnormal and emergency operating conditions. In addition to checking computer databases, software applications and embedded systems for potential Y2K problems, pipeline operators should review their procedures and contingency plans to determine if they are adequate to assure safety on January 1, 2000.
The Office of Pipeline Safety will fully consider a company’s Y2K preparation if a violation or incident results from a Y2K problem. Any subsequent compliance action will be mitigated because of these preparations. However, the Office of Pipeline Safety will pursue strong enforcement action, including maximum civil penalties, for violations by any pipeline company which does not prepare for potential Y2K problems and thereby endangers the public or the environment.
Visit the American Petroleum Institute webpage (www.api.org/y2k) for useful information for petroleum pipeline companies. The American Petroleum Institute serves as the umbrella organization for petroleum pipeline companies on the President’s Council Y2K Oil and Gas Workgroup.
Determining tasks covered under the new Operator Qualification rule is a priority for most pipeline operator’s. Some tasks, such as valve maintenance and cathodic protection surveys definitely pass the 4 part test without much question from any operator. However, there are some tasks whose status as covered or not covered is not quite as clear. One such task is right-of-way flyovers. How does this task do in the four-part test:
- Is it performed on a pipeline facility?
The pipeline right-of-way is included in DOT’s definition of a pipeline facility. You are flying over the right-of way but looking for things on the right-of-way. Is this task performed on the right-of-way?
- Is it an Operations and Maintenance task?
This is not even questionable. Right-of-way inspections are considered part of the routine maintenance of the pipeline system.
- Is it performed as a requirement of 49 CFR Part 192 or 195?
This is also a given. 49 CFR Part 192.705 and 195.412 require routine inspections of the pipeline right-of-way.
- Does it affect the operation or integrity of the pipeline?
This part of the test can also raise questions concerning this task. The results of this task can show that a pipeline is having integrity problems. However, does this have a direct effect on the operation and integrity of the pipeline?
What do you think about these questions? Please email your comments on these or other tasks that you would like to have included in future newsletters to tina@your-rcp.com.
RSPA held a public meeting on their continuing efforts to prevent damage to underground facilities on October 28, 1999. RSPA is facilitating the establishment of a nonprofit organization to advance underground facility damage prevention. Participation from all stakeholder organizations in the damage prevention community will be necessary to ensure the most effective forum to share information.
RSPA will hold a public meeting on November 18, 1999 from 9 a.m. to 4 p.m. through November 19, 1999 from 9 a.m. to Noon, at the Hyatt Dulles Hotel, 23 Dulles Corner Boulevard, Herdon, VA. This meeting will consider the need for additional safety and environmental regulations for gas transmission lines and hazardous liquid pipelines in high-density population areas, waters where a substantial likelihood of commercial navigation exists, and areas unusually sensitive to environmental damage.
The Office of Pipeline Safety intends to incorporate a process into its regulations to validate pipe integrity in these high consequence areas. The purpose of the meeting is to determine the extent to which operators now have integrity management programs, to explore effective ways to promote their development and implementation by all operators, and to discuss mechanisms by which OPS could confirm the existence and adequacy of such operator-developed programs. The meeting will discuss a practical definition of high consequence areas, as well as the need, if any, for increased inspection, enhanced damage prevention, improved emergency response, and other measures to prevent and mitigate pipeline leaks and ruptures in the area.
Anyone wishing to make an oral presentation at the meeting should notify Jenny Donohue no later than November 12, 1999 by phone (202-366-4046) or by email (donohuej@rspa.dot.gov). Written comments may be submitted to the Dockets Facility by December 20, 1999.
- RCP will have a review / discussion on the proposed MMS Pipeline Rule on at our Houston Offices the week of November 8th. Please call Bill Byrd at 225-755-7760 or 713-655-8080 or send email if you are interested in participating.
- RSPA will hold a Public Meeting on November 4, 1999, from 1:00 – 5:00 in Room 8236 of the Nassif Building, 400 Seventh Street, SW, Washington D.C. to consider the need for a rulemaking to establish time limits for isolating ruptured pipelines. The meeting agenda will include presentation of findings from a recent OPS study on remote control valves and opportunity for public comments and suggestions. The public is encouraged to present oral remarks at the public meeting. If you want to make an oral presentation at the meeting, please notify Jenny Donohue no later than October 28, at 202-366-4046 or send email to jenny.donohue@rspa.dot.gov. Written comments may be submitted prior to December 6, 1999 by mail or hand delivery. Comments should identify docket number RSPA-97-2879. The original comment and one copy should be submitted.
Written comments may be submitted prior to December 6, 1999 by mail or hand delivery. Comments should identify docket number RSPA-97-2879. The original comment and one copy should be submitted. Written comments may also be submitted electronically to the docket at http://dms.dot.gov.
Supplemental information concerning this possible rulemaking may be found in the Federal Register October 5, 1999, which is available on the RCP Website.
Heather Roark
Jessica Foley
