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DOT Pipeline Compliance News August 2004 Edition Recent Trends in DOT Pipeline Regulations |
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| Gas Pipeline Advisory Notice | Top | ||||||||||||
Gas pipeline operators are required by 49 CFR 192.945 to make their first semi-annual submission
of integrity management performance measures by August 31, 2004. The four overall performance
measures that gas transmission pipeline operators are required to submit are:
RSPA/OPS expects that the electronic submission form to be created for the August 2004 submissions
will indicate the form in which data will be collected for future intervals, but that those data
fields will be inoperable for this reporting cycle. Likewise, operators reporting by mail or facsimile
need not include numerical data related to the four overall performance measures, and should simply
indicate that they began assessment activities by the required date. RSPA/OPS will provide additional
advice regarding reporting for specific performance measures at a later date, if needed.
For a copy of the full advisory notice, contact Laura Wager at lwager@your-rcp.com.
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DOT Pipeline Compliance / Integrity Assessment Workshop
September 28 - 30, 2004 - Houston | Top | ||||||||||||
RCP will conduct a 3-day workshop on DOT Pipeline Regulations on September 28 - 30 in
Houston.
For more information or to register, you may visit our website
www.your-rcp.com/seminars or call
Maria at 1-888-727-9937.
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| NTSB Recommendations Concerning Pipe Transportation | Top | ||||||||||||
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On July 1, 2004, the National Transportation Safety Board made the following safety recommendations to the Research and Special Programs Administration:
Remove the exemption in 49 Code of Federal Regulations 192.65 (b) that permits pipe to be placed in natural gas service after pressure testing when the pipe can not be verified to have been transported in accordance with the American Petroleum Institute's recommended practice RP 5L1. (P-04-01)
Amend 49 Code of Federal Regulations to require that natural gas pipeline operators (Part 192) and hazardous liquid pipeline operators (Part 195) follow the American Petroleum Institute's recommended practice RP 5LW for transportation of pipe on marine vessels. (P-04-02)
Evaluate the need for a truck transportation standard to prevent damage to pipe, and, if needed, develop the standard and incorporate it in 49 Code of Federal Regulations Parts 192 and 195 for both natural gas and hazardous liquid line pipe. (P-04-03)
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| Standards of Performance for Stationary Gas Turbines - Final rule; Amendments | Top | ||||||||||||
The EPA has promulgated amendments to several sections of the standards of performance for
stationary gas turbines in 40 CFR part 60, subpart GG. The amendments will codify several
alternative testing and monitoring procedures that have routinely been approved by EPA.
The amendments will also reflect changes in nitrogen oxides (NOX) emission control technologies
and turbine design since the standards were promulgated. Regulated categories and entities
include any industry using a stationary combustion turbine as defined in the final rule, including:
The final rule is effective July 8, 2004. The incorporation by reference of certain publications in the final rule is approved by the Director of the Office of the Federal Register as of July 8, 2004. The EPA has established a docket for this action under Docket ID No. OAR-2002-0053. For the full text of the final rule, the file can be downloaded here ( Gas Turbine Standards Update ) or contact Laura Wager at lwager@your-rcp.com. Shameless Commerce Plug: Did you realize that RCP also handles Title V air permit applications, reporting, and site compliance manuals? |
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| ASME B31Q Industry Teleconference Recap (July 2, 2004) | Top | ||||||||||||
On July 2, 2004, various members of the ASME B31Q committee provided brief updates on the status
and future of the upcoming Operator Qualification regulatory changes. The committee has not finalized
anything yet, so take these notes with a large grain of salt because things could change (although
not expected).
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| Liquefied Natural Gas Facilities; Clarifying and Updating Safety Standards | Top | ||||||||||||
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On March 10, 2004, RSPA published a final rule that amended regulations in 49 CFR part 193 related
to the fire protection of LNG facilities used in gas pipeline transportation
( 69 FR 11330; Docket No. RSPA-03-14456). An amendment to 49 CFR 193.2005 clarified that the fire
protection requirements of part 193 (contained in § 193.2801, Fire protection) apply to LNG
facilities existing on March 31, 2000. In addition, an amendment to § 193.2801 clarified which
provisions of NFPA 59A, "Standard for the Production, Storage, and Handling of Liquefied Natural
Gas (LNG)" were incorporated by reference. That amendment also provided an extended compliance
time for actions to be taken regarding certain systems and personnel qualification. A separate
amendment updated all part 193 references to the 1996 edition of NFPA 59A to the 2001 edition of
that standard.
By letter dated April 8, 2004, the American Gas Association, a trade association representing operators of LNG facilities, submitted a petition for reconsideration of the final rule as it relates to the fire protection requirements of § 193.2801. RSPA’s response of July 12, 2004, rejected AGA’s petition, and gave additional information concerning RSPA’s interpretation of the new rule requirements. For a complete copy of RSPA’s response, please contact Laura Wager at lwager@your-rcp.com. |
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| Procedural Change for Annual NPMS Submission Updates | Top | ||||||||||||
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The Office of Pipeline Safety has implemented a procedural change to the pipeline operators' annual
NPMS submission updates. Operators may now perform these updates through the NPMS Web site
(http://www.npms.rspa.dot.gov/). Follow the link on the
home page marked "Update Your Submission
Online" to access this application. Through this interface, pipeline operators can inform the National
Repository that
their data and public contact information have not changed, or that they plan to resubmit.
Operators must update their data or confirm it as accurate every 12 months in order to comply with
the Pipeline Safety
Improvement Act of 2002. Previously, operators could notify OPS that their data had not changed by
sending an email to opsgis@rspa.dot.gov. Although that option is still available, OPS prefers that
operators
update their submissions through this Web-based application.
The application allows an operator to view geospatial information, attributes, and public contact information by submission or for an operator ID (OPID) as a whole. The operator may also verify contact information and submission dates. The application will provide the annual due date for an operator's NPMS submission. Resubmission of data will continue to be handled through the National Repository. To access the application, pipeline operators need a Pipeline Integrity Management Mapping
Application (PIMMA) username and password. If an operator already has a PIMMA username and password,
he or she may use it. If an operator has forgotten his or her username or password, please contact
National Repository staff at npms-nr@mbakercorp.com or 703-317-6205.
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| Gas Pipelines in Liquid Integrity Management Plans | Top | ||||||||||||
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The American Petroleum Institute (API) and the Association of Oil Pipeline (AOPL) have submitted two
petitions to DOT/OPS to amend Title 49 CFR Part 195.452. While most API member companies are primarily
engaged in the transportation of hazardous liquids, some of the members do operate small amounts of gas
pipelines that are subject to the Part 192 Subpart O Pipeline Integrity Management Rule.
Acceptance of the petition would allow operators to incorporate their gas pipelines into their
hazardous liquid pipeline integrity management program under Part 195.452.
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| Fire Safety Analysis Manual for LP-Gas Storage Facilities | Top | ||||||||||||
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With a consultant as a member of the NFPA, we at RCP Inc. try to benefit our newsletter recipients
with the latest opportunities to enhance protections and to mitigate potential incidents/emergency
conditions. The NFPA, National Propane Gas Association (NPGA), and the Propane Education and Research
Council (PERC) have issued a new Fire Safety Analysis Manual, which provides forms and a step-by-step
method for completing a written Fire Safety Analysis (FSA) as required in the 2001 edition of NFPA 58,
LP-Gas Code. Complying with the important requirement for a written Fire Safety Analysis (FSA) for
all LP-gas storage installations of more than 4,000 gallons water capacity (wc) can now be
accomplished with greater ease. The following links are attached for access to the manual (and the appendix that has materials
for specific follow up).
View the fire safety manual here View the Appendix here In addition to providing a valuable tool for system installers, operators of LPG facilities, and enforcement officials, the FSA Manual serves as a valuable reference for LPG operators. This is especially true for those who may be new to the LPG facility business or are unfamiliar with LP-gas facilities and the improvements made to product control features. The philosophy of NFPA 58 is to minimize fires by minimizing the accidental release of propane if an accident should occur, or in simple terms; no fuel, no fire. The manual does not address the following:
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If you have a regulatory-issue meeting planned, let us know,
and we'll announce it in both our Vessel and Facility Newsletter and our DOT Pipeline Newsletter.
Yours, W. R. (Bill) Byrd, PE President RCP Inc. 888-727-9937 wrbyrd@your-rcp.com www.your-rcp.com RCP - Your Regulatory Compliance Partner! http://www.your-rcp.com or call us at 1-888-RCP-X-YES to see what we can do for you. | |||||||||||||