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, interpretations and pending regulatory deadlines.

Q:  Is a spill of diesel fuel from a tank used to refill company vehicles at a crude oil pumping station considered to be a PHMSA-reportable spill?

A: PHMSA’s regulations in 49 CFR 195.50 require accident reporting for “a release of the hazardous liquid or carbon dioxide transported.”  Since the facility in question does not transport diesel fuel, the spill is not reportable to PHMSA.  Note that it may be reportable to other state or federal agencies. 

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.