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In This Issue

  1. RCP’s VP of Project Development to Speak at the Southern Gas Association’s Public Awareness Workshop, March 23-24
  2. OPS Issues New Liquid Pipeline Integrity Management Inspection Protocols
  3. Integrity Management Plan Up-to-Date?
  4. GAS IMP Oversight Implementation and Inspection Protocol Workshop Presentation Materials Available
  5. Operator Qualification Programs – Direct final rule
  6. Operator Qualification Update – B31Q Comments
  7. Questions Regarding OPA 90 Containment Credits?
  8. Response Plans for Onshore Transportation-Related Oil Pipelines; Final Rule
  9. Are Your Response Plans Current?
  10. Texas Pipeline Regulations – Proposed Revisions
  11. Need help with the new Stormwater Pollution Prevention Plan (SWPPP) deadline?
  12. New Research and Innovative Technology and Pipeline and Hazardous Materials Safety Administrations Announced
  13. Need to update your Public Awareness Program?
  14. Three-Digit Dialing Roll Out Planned for March 10
  15. Air Permit Needs?
  16. API Publishes RP 1133, Guidelines for Onshore Hydrocarbon Pipelines Affecting High Consequence Floodplains, First Edition
  17. RCP’s Fantastic 1-Page Version of New SPCC Regulation
  18. Railroad Commissioners Approve Pilot Project To Help Conserve Water At Drilling Sites
  19. O&M Manual Up-To-Date?
  20. RCP Services Spotlight – Underwater Inspection Procedures and Interval Risk Modeling

Operator Qualification Update – B31Q Comments

The ASME B31Q committee charged with developing the new pipeline operator qualification standard made the draft version available for public comment on February 2, 2005. Although the comment period is now closed, there have been numerous comments made to the B31Q committee. A meeting was held in Houston last week to consider the comments submitted. However, RCP understands that the committee was not able to complete this review and plans to meet again in April to review and consider the remaining comments. A few comments submitted to the committee include:

  • Provide a general provision to allow operator’s an option to “provide alternative processes for meeting the mandatory requirements of the standard provided the alternative processes can be justified”.
  • Allow the operator the option of devising an alternative approach to handling “Shall” statements as long as the operator is prepared to justify the approach.
  • Allow for individuals qualified under a previous OQ Program to be considered qualified under this standard until the time they need to meet the subsequent qualification requirements of the standard.
  • Move the responsibility of the pipeline operator to administer, oversee and audit the training and evaluation programs of contractors to the contractor for their employees. Contracts state that personnel performing work on the pipeline must be qualified and existing programs list the qualification methods the operator finds acceptable.
  • Remove Integrity Management “data analysis or decision making” tasks. This also includes gathering, analysis, evaluation and management of pipeline integrity data.
  • Agree with including “activities and tasks conducted during the construction, installation, and commissioning of a pipeline” as long as proper clarity is provided in the key terms throughout the standard that relate to the type of facility that is impacted or the nature of the task intended to be included.
  • The non-mandatory task list was not reviewed in great detail due to lack of time. However, a comment was made to extend the one year interval for qualification of Control Center personnel.
  • Provide “elements” of a training program rather than “requirements”
  • Give more latitude to expand subsequent qualification intervals.
  • Allow greater flexibility in selecting clearly defined evaluation methods for subsequent qualification evaluations.
  • Remove the portability section of the standard and include a statement in the program describing the process for accepting portable qualifications, including those from industry associations and other third party qualification providers.
  • Less prescriptive section for determining the programs effectiveness in meeting expected goals.
  • Leave the section on Program Communication and Managing Change brief. Require programs to gave a process and give guidance on what type of program information and changes require communication. Allow the operator to establish the type of communication and documentation that works best for their plan and operations.