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DOT Pipeline Compliance News
July 2007 Edition
DOT Pipeline Compliance Workshop - September 25 & 26
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RCP will be hosting our very popular workshop on DOT Pipeline Compliance on September 25 and 26 in Houston, TX.
Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance. This workshop has been attended
by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline
regulations, and is appropriate for people who are new to pipeline regulations, or who could use a refresher.
Day 1: Gas Pipeline Regulations (49CFR192)
Day 2: Liquid Pipeline Regulations (49CFR195)
Introduction to DOT/PHMSA Pipeline Regulations:
- Agency jurisdictions - what does DOT/PHMSA regulate anyway?
- Important definitions
- Important letters of clarification from the agency
- Recent EPA/DOI memorandums of understanding
- State and Federal program variations, roles and responsibilities
- Gas and liquid design, construction, operations, maintenance, and emergency response requirements
- Spill response planning requirements
- How to monitor rulemaking activity and stay current with your compliance program
- Discussion of potential rulemaking - liquid gathering rules, controller certification, etc.
For additional information, including a seminar brochure, go to our website here.
THLPSS Teleconference on Low-Stress and Rural Liquid Pipeline Regulations [Docket No. PHMSA-98-4470]
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The Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet on Tuesday, July 24, from
1 p.m. to 4 p.m. EST by telephone conference call to vote on a proposal to extend pipeline safety regulations to
certain unregulated hazardous liquid gathering lines and low-stress pipelines and on a supplemental proposal addressing
new requirements for low-stress pipelines in the Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (
PIPES Act). PHMSA will also consult with the THLPSCC on a concept addressing internal corrosion issues in hazardous
liquid pipelines.
This supplemental proposal would apply all Federal hazardous liquid pipeline safety regulations to currently
unregulated low-stress pipelines meeting certain criteria. These proposals will help protect unusually sensitive
areas from the potential adverse impacts of releases from unregulated hazardous liquid pipeline in rural areas.
Members of the public may attend the meeting at the U.S. Department of Transportation (DOT), 1200 New Jersey Ave., SE,
East Bldg., 2nd floor, Washington, DC 20590, Room E27-302. Members of the public who want to make an oral statement
should notify Cheryl Whetsel at (202) 366-4431 or by email at cheryl.whetsel@dot.gov
before July 17. Comments regarding this meeting should reference Docket No. PHMSA-98-4470. You may send or deliver your
comments to DOT's Docket Facility or send them electronically by the Web page http://dms.dot.gov.
New 2007 API RP 753 – Management of Hazards Associated with Location of Process Plant Portable Buildings
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The American Petroleum Institute has issued the 1st edition, "Management of Hazards Associated with Location of
Process Plant Portable Buildings." Developed for refineries, petrochemical and chemical operations, natural gas
liquids extraction plants, and other facilities such as those covered by the OSHA Process Safety Management Standard,
29 CFR 1910.119. API RP 753 provides guidance for reducing the risk to personnel located in portable buildings (i.e.,
light wood trailers) from potential explosion, fire, and toxic release hazards. To order API RP 753, contact IHS via
their website> or (877) 413-5187.
PHMSA 2007 R&D Forum - Request for White Papers
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The U.S. Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA) held a
Government and Industry Pipeline R&D Forum on February 7-8, 2007 in New Orleans, Louisiana. As a result of this forum,
PHMSA is seeking white papers on individual projects or on consolidated programs that address pipeline safety program
areas:
- Pipeline Damage Prevention,
- Detection and Characterization,
- Defect Remediation and Repair,
- New Fuels Transportation.
The R&D Forum led to a common understanding of current research efforts, key challenges facing government and
industry, and potential research areas where exploration can help meet these challenges, and should therefore be
considered in developing new research and development applications. The 2 day event included representatives from
Federal, State and international government agencies, public representatives, research funding organizations, standards
developing organizations, and pipeline operators from the U.S., Canada and Europe.
For more information about the forum and how to submit a white paper can be found here.
Integrity Management Services
RCP can assist pipeline operators with ongoing compliance management and engineering associated with your IMP.
This includes direct assessment strategies, tool and vendor selection, ILI/ECDA report analysis, corrosion control
programs, repair strategies, and IMP/risk model updates. For more information on how RCP can support your ongoing IMP
needs,
click here.
PST 2007 Conference – November 15 & 16
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The Pipeline Safety Trust will be hosting another pipeline safety conference: Increasing Pipeline Safety through
Shared Planning; A conference for all stakeholders. The agenda is under development but will include topics such as:
- The need for land use policies affecting the siting, width, and other characteristics of new pipeline corridors.
- Setbacks and other measures that could be adopted to protect structures that are built and maintained near pipelines.
- Development of industry best practices for the specification, acquisition, development and maintenance of pipeline ROW.
- The need for the Federal Government to develop guidance about appropriate vegetation and environmental management practices
that would provide habitat for some species, avoid threats to pipeline integrity and allow for pipeline operators' regulatory
obligations to maintain ROW to inspect pipelines.
- Raise the awareness of the risks and hazards of encroachment on pipeline ROW.
- Formation of the Pipelines and Informed Planning Alliance (PIPA)
The conference will be held at the Hotel Monteleone in the French Quarter in New Orleans, Louisiana. Registration and more
information can be found here.
TRRC Issues Final Rule: Chapter 18 – Underground Pipeline Damage Prevention
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The Texas Railroad Commission (TRRC) adopted Chapter 18, Underground Pipeline Damage Prevention, as part of the Texas
Administrative Code (TAC), and was published in the Texas Register on June 15, 2007. The new rule is effective September
1, 2007.
TRRC adopted §§18.1 – 18.12 of the new Chapter 18, entitled Underground Pipeline Damage prevention (with changes to the
proposed versions published December 22, 2006) relating to:
- Scope, Applicability, and General Provisions;
- Definitions;
- Excavator Notice to Notification Center;
- Excavator Obligation to Avoid Damage to Underground Pipelines;
- Operator and Excavator Obligations with Respect to Positive Response;
- General Marking Requirements;
- Excavator Marking Requirements;
- Operator Marking Requirements;
- Options for Managing an Excavation Site in the Vicinity of an Underground Pipeline;
- Excavation within Tolerance Zone;
- Reporting Requirements; and
- Penalty Guidelines.
The new rules in Chapter 18, with some stated exceptions, would apply to all persons engaged in or preparing to engage
in the movement of earth in the vicinity of an intrastate underground pipeline containing flammable, toxic, or
corrosive gas, a hazardous liquid, or carbon dioxide. However, the legislation amending Texas Natural Resources
Code, §117.012, and Texas Utilities Code, §121.201, specifically authorizes the Commission to exempt other entities
or occupations if the Commission determines in its rulemaking process that exempting those entities or occupations
from the rules is either in the public interest or not likely to cause harm to the safety and welfare of the public.
The Commission gives notice that one result of this rulemaking may be the exemption of additional entities and/or
activities from the new rules in Chapter 18.
Although there are some specific requirements for both excavators and pipeline operators set forth in the proposed
new rules, generally the Commission attempted to avoid provisions that would either duplicate or contradict the
mandates of Texas Utilities Code, Chapter 251, the Underground Facility Damage Prevention and Safety Act. There may
be persons exempt from the provisions of Texas Utilities Code, Chapter 251 that would be required to comply with this
chapter.
For a copy of the final rule language, go to this
website.
Damage Prevention Plans
RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you
with your Damage Prevention Plan,
click here.
New York State -- Pipeline Security Legislation
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The New York State legislature passed a bill adding a new §715 that will provide authority to the state Department
of Homeland Security to conduct a review and inspect aviation fuel tanks and pipelines and make any appropriate
recommendations to strengthen those facilities. The legislation also provides authority for the state Public Service
Commission to require by regulation that the recommendations be implemented. As deemed appropriate, the office of
homeland security shall have the authority to:
- Physically inspect the premises
- Review any audits or reports related to the security of such critical infrastructure
The Governor is expected to sign the bill. This bill was introduced in the wake of the alleged plot to blow up
tankage and pipelines providing fuel to JFK International airport.
For a copy of the new bill, contact Jessica Roger.
Need A Security Plan or Audit?
We have the expertise to develop a security plan and perform risk assessments for pipeline and terminal
facilities to meet recent DOT Hazmat Transportation & Pipeline regulations. We can also assist you in USCG
security plans for dock facilities and vessels. Please contact
Jessica Roger for more information.
2007 International Pipeline Security Forum
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The 2007 International Pipeline Security Forum will be held on October 24 & 25, 2007 at the Fairmont Chateau Laurier
Hotel in Ottawa, Ontario, Canada. The agenda is currently being developed. Additional information on the Forum,
registering procedures, and agenda will be posted on the
Transportation Security Administration (TSA) website as it becomes available.
TRRC Proposed Rulemaking – Re-adopt Chapter 8, Pipeline Safety Regulations
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The Railroad Commission of Texas filed a notice of intention to review and re-adopt 16 TAC Chapter 8 relating to
Pipeline Safety Regulations. This review is being conducted in accordance with Texas Government Code §2001.039. The
agency's reasons for adopting these rules continue to exist. The comment period ended on June 25, 2007. The status of
Commission rulemakings in progress is available at the Railroad Commission website.
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About RCP
RCP is a widely respected provider of professional engineering services and regulatory expertise to
the energy industry. Our broad, deep skills and experience translate to a thorough understanding of
the operational and regulatory issues clients face. This enables RCP to deliver comprehensive
solutions, implementation assistance, and ongoing support, and has made us a trusted partner to the
companies we serve.
Newsletter Subscription
You can subscribe to the DOT Pipeline Compliance newsletter on our website or you can e-mail your request to:
wrb@your-rcp.com
We rely on reader input to keep the newsletter contents interesting, so if there's a topic you would like discussed, send it to us via email.
Upcoming Meeting? If you have a relevant regulatory meeting planned, please let us know, and we'll announce it in our upcoming DOT Pipeline Newsletters.
More About RCP
For additional information on RCP, please visit: your-rcp.com or Contact Jessica Roger at 1-888-727-9937 for more info.
Careers at RCP
RCP is actively seeking top pipeline professionals for the following positions:
If you know of someone who might be interested, they can submit their resume to our HR department.
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