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, regarding interpretations and pending regulatory deadlines. Q: We have a gas pipeline adjacent to a refining / chemical facility. How should I count the buildings in the facility…
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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 December 2022, PHMSA issued 1 WL, 4 NOAs, 1 CAO, 1 NOPSO, and 8 NOPVs accompanied by $492,200 in proposed fines. Significant proposed fines were attributed to…
Did you know?
The Solution is Here. America has the energy resources, innovation, and skilled workforce to meet energy needs while continuing to reduce emissions. But we need the policies to make it happen. API has a plan to protect America from energy challenges together. It’s a plan in three parts – to Make, Move, and Improve American…
RIN2 Compliance Enforcement Discretion
In relation to its final rulemaking entitled “Pipeline Safety: Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments,” PHMSA is providing notice that it will exercise regulatory enforcement discretion against operators of existing onshore gas transmission pipelines in service as of the publication date of…
PHMSA Pipeline Safety: CY 2023 D&A Random Rate and MIS Reporting
[Docket No. PHMSA-2022-0137] PHMSA announced that it has determined that the minimum random drug testing rate for covered employees will be reduced to 25 percent during calendar year 2023 (effective January 1, 2023, through December 31, 2023). Operators are reminded that drug and alcohol testing information must be submitted for contractors who are performing or…
California State Fire Marshall Amends Enforcement Proceedings
The California State Fire Marshall has updated their hazardous liquid regulations associated with enforcement proceedings. Several new sections have been added to State Fire Marshall code under Chapter 14 – Hazardous Liquid Pipeline Safety, Article 6. Enforcement Proceedings. These new and amended regulations address how hazardous liquid pipeline operators and the State Fire Marshall address…
Texas Railroad Commission 2023 Pipeline Mileage Fee Due April 1
Pipeline operators need to prepare for the 2023 pipeline mileage fee that is due on April 1. The annual mileage fee is calculated using pipeline permit mapping information supplied by the operator. The miles in each permit of Group A and Group B pipelines are added together and rounded up to the nearest mile. The…
Texas Railroad Commission Notice to Pipeline Operators: Gathering Line Mileage Fee and Permit Clarification
On November 15, 2021, PHMSA published a final rule titled “Pipeline Safety: Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments.” The final rule makes changes to the federal pipeline safety regulations to improve the safety of onshore gas gathering pipelines. Operators of certain Type C…
Arkansas Gas Pipeline Regulations Update
[Docket No. 22-020-R] Arkansas updated its gas pipeline regulations to harmonize them to the federal gas pipeline regulations. Arkansas, in general, republished the federal requirements into the state regulations. However, there are exceptions. In some of these exceptions, Arkansas did not adopt the federal rules as written in 49 CFR 191 and 192 and instead…
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 November 2022, PHMSA issued 1 WL, 6 NOAs, and 5 NOPVs accompanied by $254,700 in proposed fines. Significant proposed fines were attributed to the following code sections:…
Did you know?
INGAA and its members are strongly committed to ensuring the security, reliability, and resilience of natural gas transmission pipelines, and work diligently to secure and protect their cyber and physical assets every day. Whether the threat stems from a natural event, criminal or terrorist activity, or a cyber attack, the design and operational attributes of…
Temporary Repair and Permanent Repair Frequently Asked Questions
On November 2, 2022, PHMSA issued new Frequently Asked Questions (FAQs) as guidance to pipeline operators to help them understand how to comply with existing temporary repair and permanent repair regulations. Although FAQs are not enforceable, an operator who is able to demonstrate compliance with the FAQs is likely to be able to demonstrate compliance…
PHMSA Public Meeting Addressing Multiple Pipeline Safety Topics
December 13-15, 2022 | Houston, Texas PHMSA is holding an informational public meeting to address multiple safety topics including progress on reduction of methane emissions, energy transformation, safety bulletins, and National Transportation Safety Board recommendations. The informational public meeting will be held on December 13-15, 2022, from 8:30 a.m. until 4:30 p.m. at the Westin…
GAO Recommendations for Improving PHMSA’s Enforcement Transparency Website
As you are aware, PHMSA inspects interstate natural gas and hazardous liquid pipelines, investigates accidents, and enforces laws and regulations. PHMSA puts information about its enforcement activities on its public Enforcement Transparency website. The US Government Accountability Office (GAO) issued a report and 3 recommendations related to improving the PHMSA Enforcement Transparency website. Recommendation #1:…
FERC LNG Notice of Proposed Rulemaking
[Docket No. RM22-8-000] The Federal Energy Regulatory Commission (FERC) proposes to revise its regulations under 18 CFR parts 153 and 380 governing liquefied natural gas (LNG) facilities subject to sections 3 and 7 of the Natural Gas Act by removing outdated references for seismic hazard evaluations and seismic design criteria for LNG facilities. In their…
Did you know?
The ability of the gas system to meet seasonal and peak day demands and to reliably deliver natural gas, even during high-impact events, represents an important and valuable resource that must be considered when designing future energy systems and building pathways to a low-carbon future. “Enhancing and Maintaining Gas and Energy System Resiliency”, a study…
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 October 2022, PHMSA issued 1 WL, 1 NOA, and 3 NOPVs accompanied by $1,216,602 in proposed fines. Significant proposed fines were attributed to the following code sections:…
PHMSA’s Response to AGA’s RIN 2 Petition
PHMSA has formally responded to AGA’s Petition for Reconsideration regarding the Transmission Mega Rule RIN 2. On September 23, 2022, the American Gas Association (AGA) submitted a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) petitioning the agency for reconsideration of the final rule titled “Pipeline Safety: Safety of Gas Transmission Pipelines: Repair…
Save The Planet – Drink Jack Daniels!
[as if we needed one more reason] On October 17, 2022, TC Energy Corporation announced a $29.3 million investment in a renewable natural gas (RNG) production facility near the Jack Daniel Distillery in Lynchburg, TN. Owned by Lynchburg Renewable Fuels LLC, the facility will produce RNG with a carbon intensity score that is 50 per…
RCP’s Anniversary Game
You keep playing, so why stop now? Since none of us got to enjoy 2020 OR 2021 the way we planned, RCP has decided to have ANOTHER do-over of our 25th anniversary in 2022. Let the third round of our 25th anniversary contest continue! Every month between now and December 2022, RCP will be giving…