Natural Gas Pipeline Safety Seminar
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1 Natural Gas Pipeline Safety Seminar State College, PA October 5 & 6, 2004 Pennsylvania PUC Transportation Safety Institute
2 Don McCoy Transportation Safety Institute (405)
3 NTSB TSA FRA FAA CG FTA NHTSA RSPA DOT TSI OPS TSC HMT
4 Secretary Department of Transportation
5 Administrator Research & Special Programs Administration
6 Associate Administrator Office of Pipeline Safety
7 Pipeline Safety Websites tsi.dot.gov ops.dot.gov primis.rspa.dot.gov
8 TSI Pipeline Safety Division Provides Training for: State State and Federal Pipeline Inspectors Industry Personnel International Info Sharing Pipe
9 Office of Pipeline Safety Strategic Plans & Assessment Technology & Standards Monitoring State Programs Compliance
10 OPS Priorities & Issues Integrity Management of Pipelines Inspection & Enforcement of Liquid Pipelines (Large/Small) Final Rule & Inspection for Gas Transmission Pipelines Clarification Of Operator Qualification Issues Pipeline Security Issues
11 OPS Priorities & Issues (continued) Re-Define Gathering Line Research & Development Projects Improved Public Awareness & Communications Relationships Between OPS/State Agencies
12 Office of Pipeline Safety Regional Boundaries Eastern Central Region Region Western Region Lakewood Kansas City Washington, D.C. Southwest Region Houston Atlanta Southern Region
13 Act of July 5, 1994 Combined all Transportation Acts into One
14 Pipeline Safety Law Replaced the: Natural Gas Pipeline Safety Act Hazardous Liquid Pipeline Safety Act Establishes the Laws and Authority for the Safety of Pipelines
15 Pipeline Safety Law The Pipeline Safety Improvement Act of 2002 Signed Into Law December 17, 2002
16 Pipeline Safety Law ~ Authorizes Funding Levels for OPS & State Agencies Through FY06 & Continues Role of State Agents ~ Increases Dollar Amounts for Civil Penalties ($100K/$1 M) ~ Specifically Requires Integrity Management Programs ~ Updates Provisions and Requirements Regarding One-Call Programs
17 Pipeline Safety Law ~ Periodic Review of Public Education Programs & Submittal to Regulatory Agencies ~ Pipeline Safety Grants to Communities ~ Verification Requirements for Operator Qualification Programs ~ Updated Pipeline Mapping Requirements Based on Security Constraints
18 Jurisdictions Pipeline A Interstate Intrastate Pipeline B
19 State Programs Section ection State Adopted: Certifications Pipeline Safety Regulations as a minimum Enforcement Authority Pipeline Safety Law
20 Compliance Section Operator shall: Comply with Applicable Safety Standards Prepare and Follow an O&M Plan Maintain Records Required by the Safety Standards Pipeline Safety Law
21 Developing A Regulation Petitions (ideas) submitted by: Industry Organizations or Operators Government Public Congress
22 Rulemaking Process Petition (idea) received NPRM (or ANPRM) drafted Internal review NPRM Published in Federal Register Comment period (normally 60 days) Public hearing or meeting (optional) Final Rule (FR) drafted Review & clearance thru RSPA Coordination thru OMB (if required) Published in Federal Register
23 Rulemaking Process Process may take months or years Affected parties encouraged to comment Preamble(s) are integral to NPRM and FR, but not enforceable DFR (direct final rule) process for non-controversial rules ~ six months or less
24 Rulemaking Process May comment electronically Use GO button in upper right to select DOT, then RSPA Only applies to Open Dockets
25 Two Types of Regulations Specification vs. No Smoking Performance
26 Specification Regulations Advantages: Easy to Determine Compliance Easy to Determine a Course of Action Uniformity of Means of Compliance
27 Specification Regulations Disadvantages Do Not Specify Level of Safety Do Not Allow for Variations in Environment, Operating, or Physical Characteristics May Require Unnecessary Cost Do Not Encourage Technology
28 Performance Regulations Advantages Allow for Adaptation to an Individual Situation Encourage Development of New Equipment Allow Economical Solutions to Achieve the Desired Level of Safety Promote Safety and Not the Letter of the Law
29 Performance Regulations Disadvantages Difficult to Determine Compliance Some operators may not understand exactly what is required, and attempts to comply may result in problems that could jeopardize safety
30 Waivers Section of Law Operator can be Waived from Compliance with a Safety Standard You are Excused Intrastate - Petition to State Interstate - Petition to Regional Office
31 Waiver Concerns Not a way to "skirt" the law Not always timely Inconsistencies among states, states/ops, and OPS No central database OPS has not always stated reasons for acceptance/rejection Not widely used by industry You are Excused
32 Regulation Construction Part Part ~ 192 (193, 195, etc.) Subpart (192)~ A thru O Section ~ Paragraph ~ a, b, c, d, etc. Subparagraph ~ 1, 2, 3, etc.
33
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