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…
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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 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…
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 March 2023, PHMSA issued 7 NOAs, 5 NOPVs, and 6 WLs accompanied by $225,500 in proposed fines. Significant proposed fines were attributed to the following code sections:…
Don’t Forget State Enforcement Actions!
Pipeline operators and excavators were assessed $470,600 for violations of the Texas Railroad Commission’s Pipeline Damage Prevention rules. Master Agreed Orders can be found on the RRC General Counsel webpage.
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. Hazardous Liquids operators that have facilities that, in the event of a failure, could affect a High Consequence Area are not required to…
Transportation Security Administration Releases Pipeline Physical Security Considerations
TSA has offered additional considerations for pipeline physical security that align with TSA’s Pipeline Security Guidelines [March 2018, Change 1 (April 2021)]. Operators are encouraged to monitor critical facilities for any suspicious activity and to engage with local authorities to educate them on the location of critical facilities. For a copy of TSA’s “Pipeline Physical…
PHMSA Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) Grant Program
On April 5, 2023, PHMSA announced a historic $196 million in grants for 37 projects spread across 19 states. This new grant program helps improve public safety, protect public health, and reduce methane emissions from natural gas distribution pipes. The Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) grant program provides nearly $1 billion in…
PHMSA Safety of Underground Natural Gas Storage Public Meeting
[Docket No. PHMSA-2023-0009] PHMSA will host a two-day public meeting titled: “Safety of Underground Natural Gas Storage Public Meeting” in Broomfield, Colorado. The purpose of the public meeting is to share important safety information with the public and industry, as well as gather input to inform future rulemaking decisions. The public meeting and forum will…
PHMSA Survey of Voluntary Adoption of API RP 1173 for Gas Distribution Systems
[Docket No. PHMSA-2022-0060] PHMSA has revised the voluntary PSMS implementation survey form for gas distribution operators and is open for a 30-day public comment period ending May 11, 2023. For a copy of the revised form, contact Jessica Foley. Comments can be submitted electronically at https://www.reginfo.gov/public/do/PRAMain. RCP Offers PSMS Development and Gap AnalysisRCP has extensive…
PHMSA Grants for Pipeline Safety Programs
PHMSA announced more than $25 million available in grant funding through its pipeline and hazardous materials safety programs. These grants are for projects that will train first responders, strengthen safety programs, improve safety, reduce environmental impacts, and educate the public on local safety initiatives. This includes projects that provide support to state inspectors for hazardous…
Texas Railroad Commission POC Electronic Filing
Effective September 1, 2023, the Railroad Commission of Texas (RRC) will no longer accept hard copy filings of Plan of Correction (POC) letters by mail. Pipeline operators must submit POC letters, including completion documentation, by email to Safety@rrc.texas.gov or online using the RRC’s Pipeline, Inspection, Permitting and Evaluation System (RRC PIPES) available on the RRC…