[Docket No. PHMSA-2021-0039] PHMSA has issued a new Notice of Proposed Rulemaking (NPRM) intended to reduce methane emissions from new and existing pipelines, including gas transmission, distribution, regulated gas gathering (Types A, B, C and offshore), underground natural gas storage facilities, and LNG facilities. Among the proposed amendments for Part 192-regulated gas pipelines are: Comments…
May 2023
PHMSA Notice of Limited Enforcement Discretion for New and Replaced Onshore Gas Transmission Pipelines (RIN 2)
On April 17, 2023, PHMSA issued a Notice of Limited Enforcement Discretion for the recently published Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments, or “RIN 2.” This enforcement discretion pertains to new and replaced onshore gas transmission pipelines and expands on the December…
PHMSA Released RIN 1 FAQ
PHMSA released a second set of Frequently Asked Questions (FAQ) related to the final rule entitled “Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments” which was published October 1, 2019. The first set of FAQ related to this rule were released December 21, 2021. There are…
PHMSA Released RIN 3 FAQ
On May 9, 2023, PHMSA published the long-awaited Frequently Asked Questions (FAQ) related to the rulemaking known as RIN #3 regarding onshore gas gathering lines now classified as Types C and R. There are 24 FAQ included in the “packet” and they can be found here. The publication is timely given the original effective date…
PHMSA CO2 Public Meeting May 31 – June 1, 2023
PHMSA announced a public meeting and forum on carbon dioxide (CO2) pipeline safety to discuss key topics such as public awareness, emergency response and effective communication with emergency responders and the public, dispersion modeling, safety measures to address other constituents besides CO2 in CO2 Pipelines, leak detection and reporting, and Geohazards. Key topics include: The…
PHMSA Property Damage Threshold
Prior to July 1, 2023, the property damage threshold used in the definition of a gas pipeline incident in 49 CFR 191.3 is $129,300. Effective July 1, 2023, the property damage threshold is revised to $139,700. Refer to the 2023 Gas Property Damage Reporting Threshold Inflation Adjustment notice for more information. Pursuant to 49 CFR…
Did you know?
DID YOU KNOW? Pipeline companies consider safety every step of the way, from planning, to construction, to maintenance. Members of the Interstate Natural Gas Association of America (INGAA) have made great strides through our widely recognized safety initiative – the “Integrity Management – Continuous Improvement” (IMCI) program, which provides a foundation for members to safely…
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 March 2023, PHMSA issued 7 NOAs, 5 NOPVs, and 6 WLs accompanied by $225,500 in proposed fines. Significant proposed fines were attributed to the following code sections:…
Don’t Forget State Enforcement Actions!
Pipeline operators and excavators were assessed $470,600 for violations of the Texas Railroad Commission’s Pipeline Damage Prevention rules. Master Agreed Orders can be found on the RRC General Counsel webpage.
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. Hazardous Liquids operators that have facilities that, in the event of a failure, could affect a High Consequence Area are not required to…