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Texas Railroad Commission O&G Monitoring and Enforcement Plan

The Railroad Commission of Texas (RRC) commissioners approved the agency’s Oil and Gas Monitoring Plan for Fiscal Year 2024. The new plan includes goals to accurately demonstrate the Commission ’s oil and gas monitoring and enforcement activities and to strategically use the oil and gas monitoring and enforcement resources. It focuses on developing a framework…

The Enforcement Corner

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations. In May 2023, PHMSA issued 4 NOAs, 13 NOPVs, and 3 WLs accompanied by $2,680,792 in proposed fines. Significant proposed fines were attributed to the following code sections:…

Q&A Section

Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators, including interpretations and pending regulatory deadlines. Q:  I am replacing pipeline segments by installing new pipe in a pipe rack to allow for a major highway reconstruction. If…

Did you know?

DID YOU KNOW? About the Furnace Rule… The U.S. Department of Energy (DOE) has proposed a rule, known as the Furnace Rule, that would ban the sale of non-condensing furnaces found in millions of American homes.

NPMS New Dataset Released May 2023

The National Pipeline Mapping System (NPMS) and PHMSA have released new HIGH Population and OTHER Populated areas as a new dataset based on the 2020 census data. Click on Version: 5 (Derived from 2020 Census) for more information and link to Download. Click here to register for our free webinar: “Unpacking the New NPMS Attribute…

Louisiana Department of Natural Resources Regulation Update for “Pipelines Transporting Carbon Dioxide”

On June 1, 2023, Louisiana Department of Natural Resources (La DNR) published new regulations updating Title 33 Part V (LR 49:909 (May 2023)) pertaining to pipelines that transport carbon dioxide. These updates included adding Section 93 to Chapter 301 with additional requirements for these pipelines, including items for vents, sensing devices, fail-safe control, and sources…

Texas Railroad Commission’s New Construction Reports Online Filing Mandatory September 1st

Effective September 1, 2023, the Railroad Commission of Texas (RRC) will no longer accept hard copy filings of Form PS-48, New Construction Report, by mail. Pipeline operators must submit New Construction Reports using RRC’s Pipeline, Inspection, Permitting and Evaluation System (RRC PIPES) available on the RRC website. Likewise, correspondence from RRC to pipeline operators on…

Did you know?

DID YOU KNOW? Natural gas and oil delivers growing economic contributions to America that were nearly equivalent to Canada’s annual GDP last year. From Pennsylvania to California, America’s natural gas and oil workforce is the backbone of communities, supporting nearly 11 million careers throughout the energy supply chain. The American Petroleum Institute (API) released new analysis on…

The Enforcement Corner

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations. In April 2023, PHMSA issued 5 NOAs, 7 NOPVs, and 6 WLs accompanied by $3,529,634 in proposed fines. Significant proposed fines were attributed to the following code sections:…

Enforcement Discretion Summary

To assist those who struggle to keep up with the rules as they change, and whose minds are quickly blown by double and triple negatives, below is a handy summary for our readers of the currently available “discretionary enforcement” items from PHMSA: 1. December 6, 2022 PHMSA issued a discretionary enforcement on December 6, 2022, for…

Q&A Section

Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators, interpretations and pending regulatory deadlines. Q:  When discovering an immediate repair anomaly do I have to take a pressure reduction if I am operating below the calculated safe…

PHMSA Issues NPRM for Gas Pipeline Leak Detection and Repair

[Docket No. PHMSA-2021-0039] PHMSA has issued a new Notice of Proposed Rulemaking (NPRM) intended to reduce methane emissions from new and existing pipelines, including gas transmission, distribution, regulated gas gathering (Types A, B, C and offshore), underground natural gas storage facilities, and LNG facilities.  Among the proposed amendments for Part 192-regulated gas pipelines are: Comments…

PHMSA Notice of Limited Enforcement Discretion for New and Replaced Onshore Gas Transmission Pipelines (RIN 2)

On April 17, 2023, PHMSA issued a Notice of Limited Enforcement Discretion for the recently published Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments, or “RIN 2.”  This enforcement discretion pertains to new and replaced onshore gas transmission pipelines and expands on the December…

PHMSA Released RIN 1 FAQ

PHMSA released a second set of Frequently Asked Questions (FAQ) related to the final rule entitled “Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments” which was published October 1, 2019. The first set of FAQ related to this rule were released December 21, 2021. There are…

PHMSA Released RIN 3 FAQ

On May 9, 2023, PHMSA published the long-awaited Frequently Asked Questions (FAQ) related to the rulemaking known as RIN #3 regarding onshore gas gathering lines now classified as Types C and R.  There are 24 FAQ included in the “packet” and they can be found here. The publication is timely given the original effective date…

PHMSA CO2 Public Meeting May 31 – June 1, 2023

PHMSA announced a public meeting and forum on carbon dioxide (CO2) pipeline safety to discuss key topics such as public awareness, emergency response and effective communication with emergency responders and the public, dispersion modeling, safety measures to address other constituents besides CO2 in CO2 Pipelines, leak detection and reporting, and Geohazards.  Key topics include: The…

PHMSA Property Damage Threshold

Prior to July 1, 2023, the property damage threshold used in the definition of a gas pipeline incident in 49 CFR 191.3 is $129,300. Effective July 1, 2023, the property damage threshold is revised to $139,700. Refer to the 2023 Gas Property Damage Reporting Threshold Inflation Adjustment notice for more information. Pursuant to 49 CFR…

Did you know?

DID YOU KNOW? Pipeline companies consider safety every step of the way, from planning, to construction, to maintenance. Members of the Interstate Natural Gas Association of America (INGAA) have made great strides through our widely recognized safety initiative – the “Integrity Management – Continuous Improvement” (IMCI) program, which provides a foundation for members to safely…