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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 a refinery (which produced the products)?

A: A Liquid gathering line “transports petroleum from a production facility.” Petroleum is defined by PHMSA to include crude oil. Petroleum Product is also a term defined by PHMSA that includes “products obtained from distilling and processing of crude oil.” Per PHMSA’s definitions, a refined products pipeline carries “petroleum products”, not “petroleum.” Thus, refined products pipelines do not qualify as gathering pipelines, regardless of their diameter or where they begin.

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Upcoming Deadlines:

  • The deadline to submit comments in response to PHMSA’s NPRM: Pipeline Safety: Gas Pipeline Leak Detection and Repair must be filed by August 16, 2023. The originally published closing date for comments was July 17, but PHMSA has extended the period an additional thirty days. Comments may be filed at Docket No. PHMSA-2021-0039.
  • 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.