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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 August 2023, PHMSA issued 1 CAO, 0 NOAs, 1 NOPSO, 6 NOPVs, and 2 WLs accompanied by $575,900 in proposed fines. Significant proposed fines were attributed to…

Did you know?

Need for sound policy – The need for sound energy policy has never been more critical. A modern U.S. infrastructure system, including robust pipeline infrastructure, is crucial to providing a reliable energy supply to every community in America. Our own resources can spur community growth and security, and we can develop American energy while protecting…

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:  As far as the New Valve Rule goes, it does not apply to poly distribution, correct? A: The New Valve Rule doesn’t…

GPAC Meeting Notice

[Docket No. PHMSA–2023–0061]  PHMSA has sent to the Federal Register for publication a notice announcing a public meeting of the Gas Pipeline Advisory Committee (GPAC) to discuss the notices of proposed rulemaking (NPRMs) titled “Gas Pipeline Leak Detection and Repair” and “Class Location Change Requirements.” PHMSA will hold a public meeting from November 27, 2023,…

Did you know?

DID YOU KNOW? Natural gas is what fuels the stoves and ovens that deliver world-class, memorable meals in restaurants and resorts. Hotels use natural gas to provide hot showers, clean linens, and to keep the lights no matter the situation. In colder climates, heated pools and saunas allow guests to relax, and fire pits keep…

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 July 2023, PHMSA issued 1 CAO, 3 NOAs, 5 NOPVs, and no WLs accompanied by $119,000 in proposed fines. Significant proposed fines were attributed to the following…

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:  Is a spill of diesel fuel from a tank used to refill company vehicles at a crude oil pumping station considered to…

Texas RRC Notices to Pipeline Operators

The Railroad Commission of Texas (RRC) issued several notices to Pipeline Operators regarding electronic or online filing for POCs and new construction reports; and, there is a new address for the Fort Worth office. Plan of Correction Letter Electronic or Online Filing Mandatory September 1 Pipeline operators must submit POC letters, including completion documentation, by…

Arkansas Damage Prevention Reg Changes

On August 14th, the Arkansas State regulations for Chapter 271 – Underground Facilities Damage Prevention were updated.  Additions, deletions and modifications were made to the definitions. New language was added to Chapter 14-271-104. Penalties – Civil Remedies. “. . .any person who damages an underground facility and violates this chapter shall be subject to a…

PHMSA PSMS Survey Now Live

The online portal for PHMSA’s Pipeline Safety Management Systems (PSMS) voluntary Information Collection Request is now available on the same portal used for Gas Distribution Annual Report submissions. Operators have until September 19, 2023, to respond. RCP Offers PSMS Development and Gap AnalysisRCP has extensive experience in developing, assessing, and implementing safety management systems. RCP subject…

PHMSA Notice of Proposed Rulemaking – Gas Distribution

[Docket No. PHMSA-2021-0046] On September 7th, PHMSA’s Notice of Proposed Rulemaking (NPRM), Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives, was published in the Federal Register.  This NPRM would require gas distribution operators to update their distribution integrity management programs (DIMP), emergency response plans, operations and maintenance manuals, and other safety practices. This…

PHMSA Pipeline Safety R&D Public Meeting Oct 31 – Nov 1, 2023

[Docket No. PHMSA-2023-0056] PHMSA announced the 2023 Pipeline Safety Research and Development Forum will be held October 31–November 1, 2023, at the Westin Crystal City, Reagan National Airport, 1800 Richmond Highway, Arlington, VA. PHMSA Pipeline Safety R&D Forum is held to generate a national research agenda that identifies technical challenges; foster solutions to improve pipeline…

Did you know?

DID YOU KNOW? Interstate Natural Gas Association of America (INGAA) members work continuously to improve practices that minimize methane emissions from interstate natural gas transmission and storage operations in a prudent and environmentally responsible manner. INGAA’s 2021 Methane Emissions Commitments outline actions the membership take on a regular basis in order to continue to reduce…

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: Can a refined products pipeline be considered a liquid gathering line if it is 8” or less in diameter and starts at…

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 June 2023, PHMSA issued 4 NOAs, 7 NOPVs, and 4 WLs accompanied by $3,429,512 in proposed fines. Significant proposed fines were attributed to the following code sections:…

Pipeline Fines Trending Up… a lot?!

Mike Soraghan with “E&E News” noted in a recent Energywire article that PHMSA’s fines for pipeline safety violations have trended significantly higher in the past couple of years.  Per the article: “Federal civil penalties for pipeline safety violations topped $10 million for the first time in 2021 and rose again last year to $11.6 million.…

PHMSA Technical Corrections to Valve Installation and Minimum Rupture Detection

[Docket No. PHMSA-2013-0255, Amdt. Nos. 192-134, 195-106] PHMSA issued editorial and technical corrections clarifying the regulations in its April 8, 2022, final rule titled “Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards” for certain gas, hazardous liquid, and carbon dioxide pipelines. (See related article in the June 2022 edition of the “DOT…