In This Issue

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:  If a liquid pipeline operator installs the wrong style of gasket in a flange during a maintenance repair, and then the joint leaks 1 barrel of oil during startup, is that considered a maintenance-related release?  Does the spill need to be reported? 

A: Liquid pipelines report spills larger than 5 gallons, unless the release is “resulting from a pipeline maintenance activity”, in which case the volume threshold is 5 barrels.  To qualify for the higher maintenance-related reporting threshold, the spill must occur as part of the maintenance activity.  Installing the wrong style of gasket is due to operator error and falls under the 5 gallon, not the 5 barrel, reporting threshold. 

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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 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.