PHMSA issued an amended corrective action order for Enable Gas due to a pipeline rupture that occurred on October 4, 2023, on its 24-inch natural gas transmission pipeline near Jessieville, Arkansas. The Enable Gas control room was alerted by the public to a possible pipeline rupture and responded to shut-in the affected segment of their 24-inch pipeline. The rupture and ignition of the pipeline caused extensive damage to nearly all aboveground piping and appurtenances at the Jessieville Junction Station. A visual inspection of the failed pipe segment by operator’s on-site personnel appeared to show an area of extensive external corrosion with one area reading 0.130 ­inches, or 46% remaining wall thickness. Prior incidents on this line occurred in 2014 and 2019 and were due to near-neutral pH stress corrosion cracking.

For more information about this CAO, please email Jessica Foley.

PHMSA has hired a contractor to update the location of Ecological Unusually Sensitive Areas for Liquid IMP HCA analysis.  The update is scheduled for Q4 2024. While we can’t pinpoint the exact release date by PHMSA, it’s likely to hit the public domain sometime in November or December 2024.  Operators will then need to use this updated dataset for their ”could affect” analysis that determines which liquid pipeline segments are required to be in their integrity management plans.

Note that PHMSA requires liquid pipeline operators to conduct a “could affect” analysis even if they voluntarily include all of their pipe segments in their IMP. 

RCP’s GIS experts will be prepared to use this new dataset to assist our clients in their HCA analysis as soon as it is released.  For further information, please message Jessica Foley.

[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, to December 1, 2023, from 8:30 a.m. to 5:00 p.m. ET to discuss the NPRMs. Members of the public who wish to attend are asked to register no later than November 20, 2023. PHMSA requests that individuals who require accommodations because of a disability notify Tewabe Asebe by e-mail at least five days prior to the meeting. Public comments on the proceedings of the GPAC meeting must be submitted by January 5, 2024. 

The meeting will be held in person at the Westin Crystal City, 1800 Richmond Highway, Arlington, VA 22202. The agenda and any additional information, including information on how to participate in the meeting, will be published on the meeting website here. Presentations will be available on the meeting website here. 

For a copy of the meeting notice, please message Jessica Foley.  

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 2023, PHMSA issued 1 CAO, 6 NOAs, 1 NOPSO, 6 NOPVs, and 4 WLs accompanied by $87,800 in proposed fines. Significant proposed fines were attributed to the following code sections:

• $87,800 – 49 CFR 195.440(c) – Public Awareness 

Please note: 

1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.  

2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final. 

3. 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. 

4. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements. 

5. 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. 

6. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred. 

7. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do. 

8. 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.