April 2024 Issue
In This Issue
- April is Safe Digging Month!
- PHMSA Extends Feedback Deadline for GPAC Public Meeting Proceedings
- Arkansas Rule D-23 – General Rule for the Regulation of Underground Natural Gas Storage Projects
- Missouri Updates Department of Commerce and Insurance Rules: What You Need to Know!
- Featured Service
- Summary of Proposed PHMSA Form Updates
- Q&A Section
- Did you know?
- The Enforcement Corner
- 2024 Conference News
- 2024 PSI Training Schedule
April is Safe Digging Month!
April marks an important time of the year as it is designated as Safe Digging Month, a period dedicated to raising awareness about the importance of safe digging practices and preventing underground utility damage.
Think again. 40% of active diggers don’t contact 811 before digging because they think their project is too shallow to require it.
The truth is, utilities can be buried just inches below the surface. The only way to know for sure is to contact 811 before any digging project. Contact www.811beforeyoudig.com.
PHMSA Extends Feedback Deadline for GPAC Public Meeting Proceedings
PHMSA has published the voting slides and transcripts from the March 25– 29 GPAC meeting, which covered the NPRM for Class Location Change Requirements and the NPRM for Gas Pipeline Leak Detection and Repair. Those slides and meeting transcripts can be found here.
On April 10, 2024, PHMSA extended the comment submission deadline for the proceedings of the GPAC by 120 days for the Class Location Change Requirements NPRM. However, the submission deadline for comments on the Gas Pipeline Leak Detection and Repair NPRM were not extended and remains as April 29, 2024.
Arkansas Rule D-23 – General Rule for the Regulation of Underground Natural Gas Storage Projects
The Arkansas Oil and Gas Commission (“OGC”) has proposed amendments to Commission General Rule D-23, “General Rule for the Regulation of Underground Natural Gas Storage Projects.” Specifically, the rule amendments are promulgated to provide for the underground storage of other gases, such as carbon oxides, ammonia, hydrogen, nitrogen, and noble gas. The OGC accepted comments up until April 15, 2024. Interested parties can review the redlined proposed general rule in person at the OGC offices in North Little Rock, Arkansas, at 5301 Northshore Drive, phone 501-683-5816; or online at the OGC website.
Underground Gas Storage
RCP is the market leader for underground gas storage integrity and risk management. We have unmatched industry leaders available to assess your program and provide practical feedback and recommendations for improving your gas storage integrity and risk programs. For more information about RCP’s underground gas storage integrity management and risk analysis services, visit our website or contact Jessica Foley.
Missouri Updates Department of Commerce and Insurance Rules: What You Need to Know!
The State of Missouri has amended the rules in the Department of Commerce and Insurance, Division 4240 – Public Service Commission, Chapter 40 – Gas Utilities and Gas Safety Standards, effective March 1, 2024. These rule changes address amendments by the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, 49 CFR Parts 191 Transportation of Natural and Other Gas by Pipeline; Annual, Incident , and Other Reporting, and 192 Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards, promulgated between January 2021 and December 2023 (i.e., RIN 3, RIN 2, RMV). The State of Missouri regulations now match those of PHMSA. This amendment also incorporated by reference the most recent version of 49 CFR Parts 40 and 199, Drug and Alcohol Testing. Below is a list of some of the additional State requirements that have been revised:
- Affiliate Transactions
- Marketing Affiliate Transactions
- HVAC Services Affiliate Transactions
- Natural Gas Price Volatility Mitigation
- Immediate Notice of Missouri Incidents
- Estimated property damage of $17,500
- Submittal of Welding/Joining Procedures and Construction Standards
- Uniform System of Accounts-Gas Corporations
- Filing Requirements for Gas Utility Rate Schedules
- Submission Requirements for Gas Utility Depreciation Studies
For a copy of the Missouri Safety Standard, contact Jessica Foley.
Featured Service
TaskOp Highlight: MOC Module
TaskOp, RCP’s reliable Workflow & Asset Management Application, features a fully integrated Management of Change (MOC) Module. Designed to meet the requirements of 49 CFR 192, 195, and PHMSA’s RIN2, Gas Mega Rule regulations as documented in § 192.13, this Module allows users to electronically oversee their company’s management of change process.
TaskOp’s MOC Module was built to manage the following aspects of any MOC process:
- Scalable approval process, with designated alternates
- Tracking of MOCs through a step-by-step process flow
- Set automatic notifications to key personnel for each process step
- Allows MOC Coordinator to track real-time updates and progress of MOC
- Provides checks and balances for modifications of process to ensure MOC security
- Comprehensive documentation of change (TVC)
TaskOp’s MOC module was specifically designed to provide ease of use while being flexible and scalable, offering robust customization options to meet increasing regulatory requirements. This module ensures a consistent and reliable experience throughout any MOC process.
If your goal is a streamlined and accessible MOC process, look no further than TaskOp’s MOC module.
From 49 CFR 192.13: “For pipeline segments other than those covered in subpart O of this part, this management of change process must be implemented by February 26, 2024. The requirements of this paragraph (d) do not apply to gas gathering pipelines.”
To learn more about the TaskOp MOC Module, click the link below to schedule a demo.
Summary of Proposed PHMSA Form Updates
[Docket No.: PHMSA-2022-0085]
Stay in the loop with the latest PHMSA proposed form changes as of March 25, 2024. Our summary provides essential insights to keep you informed and prepared.
- Operator ID Request & National Registry Notification Forms
PHMSA has added an option for Blended Natural Gas and Hydrogen Gas – a natural gas stream which is blended by intentionally injecting hydrogen gas into the stream at varying percentages. - Gas Distribution, Gas Gathering & Transmission Incident Reports
PHMSA proposes to add a question on the natural gas incident reports regarding Blended Natural Gas and Hydrogen Gas and the percentage by volume of hydrogen gas transported. - Gas Distribution, Gas Gathering & Transmission Annual Reports
PHMSA proposes to add Blended Natural Gas and Hydrogen Gas to the commodity groups that can be selected in the Natural Gas Annual Reports.
The Gas Gathering & Transmission Annual Report will require miles of pipe between a set of RMVs or alternative equivalent technologies to be entered in PART U – Miles of Onshore Pipe by Shut-Off Segment, Class Location, HCA, and Nominal Pipe Size. - Hazardous Liquids Annual Report
Miles of pipe between a set of RMVs or alternative equivalent technologies are to be entered in PART S – Miles of Onshore Pipe by Shut-Off segment, HCA, and Nominal Pipe Size.
For a copy of this notice from the Federal Register, please contact Jessica Foley.
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 regarding interpretations and pending regulatory deadlines.
Q: Do I have to do ILI on newly constructed pipe?
A: Yes, hydro is the baseline – don’t have to ILI new construction.
Ask the Experts
Do you have a question for the experts at RCP? Submit your question using this form. If your question is selected for a future newsletter, you will be eligible for a gift of your choice from RCP’s online Store.
Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will have 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.
Did you know?
The American pharmaceutical and healthcare sectors could not continue to operate as they do without natural gas and other petrochemicals. The loss of these vital feedstocks and energy sources would cripple the production of vital supplies, make sanitary care vastly harder, and raise the cost of pharmaceuticals for customers. Learn more about the critical role natural gas plays in the pharmaceutical and healthcare sectors here: Advancing America’s Pharmaceuticals: The Value of Natural Gas to U.S. Pharmaceutical Manufacturing.
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 February 2024, PHMSA issued 1 CAO, 6 NOAs, 6 NOPVs, and 6 WLs accompanied by $307,942 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $239,142 – 49 CFR 195.446(a) – Control Room Management
- $68,800 – 49 CFR 192.5(b)(3)(ii) – Class Locations
Please note:
- Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.
- Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
- A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
- A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
- A Notice of Proposed Safety Order (NOPSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
- A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
- Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
- Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.
RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course?
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends. We can help put things into context to ensure an effective reply for each citation. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
2024 Conference News
API Pipeline Conference and Expo: Pipeline, Control Room and Cybernetics
May 6-May 8, 2024 | Hyatt Regency Salt Lake City | Salt Lake City, Utah
Join over 700 industry professionals in Salt Lake City, Utah from May 6-8, 2024, as we explore the evolving landscape of energy sustainability and security. Discover how oil and gas companies are pioneering innovative solutions to climate challenges, sustaining resources today while securing the future through cutting-edge business models. Be sure to visit the RCP booth #306 to visit with our SMEs and snag some swag! Don’t miss out on this opportunity to connect, collaborate, and learn with global leaders shaping the future of energy evolution.
Click here to register for the API Pipeline Conference and Expo: Pipeline, Control Room and Cybernetics.
RCP Speakers:
Mr. Chris Foley, VP “What’s new with 192?”
Join Chris Foley as he discusses the latest changes to CFR 192, governing the transportation of natural gas by pipeline. Discover the updated safety measures, regulatory compliance requirements, and emerging challenges in the industry. Don’t miss this opportunity to stay informed and ensure the safety and reliability of natural gas transportation infrastructure.
When: Monday, May 6 at 2:50 PM | Where: Showbird
Super DUG
May 15-May 17, 2024 | Fort Worth Convention Center | Fort Worth, TX
Don’t miss SUPER DUG 2024, the premier event focusing on energy production in the U.S. shale plays, including the Permian, Eagle Ford, Midcontinent, Bakken, and the Rockies. Following last year’s successful launch, this year’s event is set to be even bigger, with over 2,000 industry professionals, 130+ exhibitors, and 10+ hours of networking opportunities. Connect with key decision-makers from public and private producers, midstream operators, and leading service and technology providers.
Click here to register for Super Dug 2024!
TGA Annual Operations and Management Meeting
June 23-June 27, 2024 | Margaritaville Lake Resort | Montgomery, TX
The TGA Annual Operations and Management Meeting, celebrating its 50th anniversary, stands as the premier event for industry professionals to explore cutting-edge trends and best practices in operations and management. Through engaging discussions, workshops, and networking opportunities, attendees collaborate to drive organizational excellence. Join us for insightful presentations and interactive sessions as we commemorate our rich history and shape the future of operational success together.
Click here to register for TGA’s Annual Operations and Management Meeting.
Florida Natural Gas Association (FNGA) Symposium & Expo
June 24-June 26, 2024 | The Westin Cape Coral Resort at Marina Village | Cape Coral, FL
Discover the latest developments in Florida and gain insights into prominent industry figures at the Florida Natural Gas Association Symposium & Expo. Engage with thought-provoking content presented by esteemed guests and participate in industry discussions designed to enhance your expertise. This event offers invaluable networking opportunities to foster connections crucial for sustaining natural gas’ prominence in energy dialogues. Explore a diverse array of industry suppliers showcasing cutting-edge technologies and innovations essential for efficient natural gas delivery to consumers. Join us to stay informed, connected, and at the forefront of advancements in the natural gas industry.
Click here to register for the FNGA Symposium & Expo.
SGA Operations Conference
July 22-July 24, 2024 | DoubleTree by Hilton Nashville Downtown | Nashville, TN
The SGA Operations Conference is a gathering for professionals in the natural gas industry, specifically tailored for individual contributors to the natural gas industry operations space. This conference provides a platform for industry leaders to share insights, discuss best practices, and explore the latest advancements in operations, asset management, gas control, and technology.
Click here to register for the SGA Operations Conference.