RCP has provided expert support for various pipeline acquisitions. The types of services we have recently provided include the following: Environmental Site Assessments (Phase I and Phase II) – An Environmental Site Assessment (ESA) is an evaluation of a property and all structures on the property to determine the likelihood of a recognized environmental condition.…
December 2003
Gas and Hazardous Liquid Gathering Lines: Notice of Public Meeting and Request for Comments
OPS has announced another public meeting to discuss the regulation of gas and hazardous liquid gathering lines (see our November 2003 newsletter for additional detail). Congress has directed RSPA to define “gathering line” for gas and hazardous liquid pipeline transportation and, if appropriate, define as “regulated gathering line” those rural gathering lines that, because of…
Passage of Internal Inspection Devices – Request for information
RSPA published regulations on Apr. 12, 1994 (59 FR 17281) requiring that, except where impracticable, operators of gas and hazardous liquid pipelines must design and construct certain pipelines to accommodate the passage of instrumented internal inspection devices, or smart pigs. In response to petitions for reconsideration from the American Gas Association and the Interstate Natural…
Pipeline Surge Tanks are DOT Regulated
Just in case you weren’t sure, in 49 CFR 195.2 the Office of Pipeline Safety makes it clear that any “tank used to relieve surges in a hazardous liquid pipeline system” is considered a breakout tank and therefore falls under DOT jurisdiction. This is the case even if EPA also regulates the tank, such as…
Gas Pipeline Advisory Bulletin: Start of Baseline Assessment
The following is the text from a November 10, 2003 advisory bulletin from OPS: Advisory Bulletin (ADB-03-07) To: Operators of gas transmission pipelines. Subject: The requirement in 49 U.S.C. 60109 (c) that each operator begin the baseline integrity assessment of segments in high consequence areas no later than June 17, 2004. Purpose: To provide guidance…
Corrosion Threat to Newly Constructed Pipelines: Advisory Bulletin (ADB-03-06)
The OPS has recently issued an advisory bulletin to advise owners and operators of natural gas transmission and hazardous liquid pipelines to consider external corrosion as a possible safety risk to newly constructed pipelines and to identify and remediate the detrimental effects of stray currents during and after construction. This action follows the discovery of…
Advisory bulletin: Self-Assessment of Pipeline Operator Public Education Programs
RSPA’s Office of Pipeline Safety (RSPA/OPS) has issued as advisory bulletin to owners and operators of hazardous liquid pipelines, gas transmission pipelines, gas distribution pipeline systems and gathering pipeline systems regulated under the Federal pipeline safety regulations at 49 CFR Parts 192 and 195. In an advisory bulletin issued September 5, 2003 ( 68 FR…