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In This Issue

  1. DOT Pipeline Compliance Workshop – Gas & Liquid
  2. Introducing TestOp®
  3. Updated PREP Guidelines
  4. Florida Gas Pipeline Siting Regulations Revisions
  5. RCP Acquisition Support / Due Diligence
  6. Pause and Reflect During This Century’s Pi Second
  7. Spring 2015 Conference Schedule
  8. Midwest Energy Association Legal, Regulatory & Government Affairs Summit
  9. Save the Dates!

Updated PREP Guidelines

[USCG Docket number USCG-2011-1178]

PHMSA requires that certain oil pipeline operators prepare oil spill response plans, including drill programs. Per 49 CFR 194.107 (c)(1)(ix), the operator must follow the USCG’s National Preparedness for Response Exercise Program (PREP) Guidelines, or have an equivalent drill program. On February 27, 2015 the USCG announced their updated PREP guidelines. Significant changes for pipeline operators include:

  • The frequency of deployment exercises for equipment that is owned by the facility, operated by an OSRO and listed in EPA-regulated plans has been changed from annually to semi-annually.
  • Oil spill surveillance and tracking systems should be identified as a type of response equipment to be exercised during internal equipment deployment exercises in order to test the policy holder’s abilities to effectively support and direct other response activities and equipment, such as the use of dispersants, in-situ burning, mechanical recovery, shoreline protection or wildlife recovery.

Comments must reach USCG by April 28, 2015. For a complete copy of the Federal Register Notice, please contact Jessica Foley.