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Pipeline Law

Category Archives: Integrity Management

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Fate of Extensive Liquid Pipeline Final Rule Uncertain

Posted in Administrative Rulemaking, Integrity Management, Operation & Maintenance, PHMSA
During the last week of the Obama Administration, PHMSA released a pre-publication copy of the hazardous liquid pipeline safety final rule, which has been six years in the making. The rulemaking was intended to address issues raised by several sources: high profile pipeline accidents; directives contained in amendments to the Pipeline Safety Act; and recommendations from the NTSB and GAO. The final rule would implement many significant and expansive inspection and reporting requirements, including periodic integrity assessments and leak detection for pipelines outside of high consequence areas (HCAs), inspections of pipelines after extreme weather events, expanded reporting, and more stringent integrity management repair and data collection requirements.… Continue Reading

Regulatory Freeze issued by New Administration

Posted in Administrative Guidance, Administrative Rulemaking, Integrity Management, PHMSA, Pipeline Safety Act
On the first day of the new Trump Administration, Chief of Staff Reince Priebus issued a Memorandum to the heads of all Executive Departments and Agencies, requesting that all federal agencies suspend transmittal of any new proposed or final rules to the Office of the Federal Register (OFR) until the new Administration’s Agency appointees have… Continue Reading

Concerns about HCA Identification Methods Prompts Advisory

Posted in Administrative Guidance, Integrity Management, Natural Gas, Operation & Maintenance, PHMSA, Pipeline Safety Act
Citing concerns that intrastate and small gas transmission pipeline operators may not be accurately identifying high consequence areas (HCAs) as part of their integrity management programs (IMP), PHMSA issued yet another advisory to the industry on December 12, 2016.  In its seventh advisory issued this year, PHMSA explains the need for further guidance on the methodology… Continue Reading

GPAC Public Meetings to Discuss PHMSA Gas Rule Rescheduled

Posted in Administrative Guidance, Integrity Management, Natural Gas, Operation & Maintenance, PHMSA, Pipeline Safety Act
PHMSA has rescheduled the public meetings of the Gas Pipeline Advisory Committee (GPAC) for January 11-12, 2017.  The purpose of these meetings is to discuss PHMSA’s proposed gas mega rule and the underlying regulatory analysis.  The meetings were previously scheduled for December 7-8, 2016, but have been rescheduled based on the availability of committee members… Continue Reading

Pipeline Blast Highlights Necessity of Proper Abandonment Procedures

Posted in Enforcement, Integrity Management, Natural Gas, Operation & Maintenance, Pipeline Safety Act
A previously abandoned natural gas pipeline exploded in Seattle, Washington on March 9, 2016, injuring nine firefighters, destroyed two buildings, and damaged multiple nearby structures.  The entity responsible for regulating intrastate and interstate gas pipelines in the state, the Washington Utilities and Transportation Commission, recently released a report from its investigation of the incident, concluding that… Continue Reading

Advisory Bulletin Warns About Corrosion Under Insulation

Posted in Administrative Guidance, Integrity Management, Operation & Maintenance, PHMSA, Policy
A recent PHMSA Advisory Bulletin warns the pipeline industry about Corrosion Under Insulation (CUI), which is frequently used on pipe transporting heavy crude oil.  Such products are often heated for more efficient transport, thus the pipe is wrapped with foam insulation over the coating, and then further covered with a tape wrap over the insulation.  The… Continue Reading

Comment Period Extended 30 Days for PHMSA Gas Proposed Rule

Posted in Administrative Rulemaking, Integrity Management, Natural Gas, PHMSA, Recordkeeping, Reporting Obligations
PHMSA announced that it will extend the comment period on its proposed gas rule by only 30 days, with comments due on or before July 7, 2016.  Due to the scope and complexity of the proposal, numerous parties requested a 60 day extension of the comment period.  In granting the 30 day extension, PHMSA noted… Continue Reading

Expansive Proposed Rulemaking Issued by PHMSA for Natural Gas Pipelines

Posted in Administrative Rulemaking, Construction & Design, Integrity Management, Natural Gas, Operation & Maintenance, PHMSA, Pipeline Safety Act, Recordkeeping, Reporting Obligations
PHMSA has released a Notice of Proposed Rulemaking (NPRM or Notice) to substantially revise that Agency’s rules (at 49 CFR Part 192) for construction, operation and maintenance of natural gas pipeline systems. … Continue Reading

Another Step Closer to Federal Regulation of Underground Storage

Posted in Administrative Guidance, Environmental, Federal/ State Legislation, Integrity Management, Natural Gas, PHMSA, Policy
The ongoing leak of methane from Southern California Natural Gas Company’s Aliso Canyon/Porter Ranch underground storage field near Los Angeles has drawn national attention to underground natural gas storage, triggering regulatory and legislative efforts to regulate these facilities at federal and state levels.… Continue Reading

Senate Pipeline Safety Act Reauthorization Bill Advances

Posted in Administrative Rulemaking, Federal/ State Legislation, Integrity Management, PHMSA, Pipeline Safety Act
A bipartisan group of Senators who serve on the Senate Committee on Commerce, Science and Transportation introduced a Pipeline Safety Act reauthorization bill in November, the Securing America’s Future Energy: Protecting Infrastructure of Pipelines and Enhancing Safety (SAFE PIPES) Act [link], Senate Bill 2276. That bill was approved by the Committee on December 9, 2015 with five amendments. … Continue Reading

Pipeline Safety Field Hearing Provides Insight to PHMSA Priorities; Second Hearing Scheduled

Posted in Enforcement, Environmental, Federal/ State Legislation, Integrity Management, PHMSA, Pipeline Safety Act
As the September 30th deadline for the Pipeline Safety Act reauthorization draws near, the Senate Committee on Commerce, Science, and Transportation convened a pipeline safety field hearing in Billings, Montana and recently scheduled a second hearing for September 29th in Washington, DC. … Continue Reading

How Will EPA’s New Definition of “Waters of the U.S.” Affect Oil & Gas Pipelines?

Posted in Administrative Rulemaking, Environmental, Federal/ State Legislation, Integrity Management, Policy
Amid considerable controversy, the U.S. EPA and Army Corps of Engineers (the agencies) issued a Final Rule on May 27, 2015, re-defining and expanding the definition of jurisdictional “waters of the U.S.” under the federal Clean Water Act. … Continue Reading

Advisory Regarding Damage to Pipelines from Flooding

Posted in Administrative Guidance, Incident Response, Integrity Management, Operation & Maintenance, PHMSA, Public Awareness/ Community Relations
PHMSA issued an updated advisory regarding the potential for damage to pipeline facilities caused by severe flooding. Presumably prompted by the January 2015 release to the Yellowstone river in Glendive, Montana, associated with an area of exposed pipeline on the river bottom, the Agency reiterated the nine (9) actions it has set forth in prior advisories to prevent and mitigate damage to pipelines impacted by flooding. … Continue Reading

PHMSA Final Rule Amends Numerous Pipeline Safety Regulations

Posted in Administrative Rulemaking, Construction & Design, Integrity Management, Operation & Maintenance, PHMSA, Pipeline Safety Act, Policy, Reporting Obligations
PHMSA issued a Final Rule that amends various Part 195 and 192 regulations relating to post-construction inspections, welding, gas component pressure testing requirements, and calculating pressure reductions for immediate repairs on liquid pipelines, among other changes.… Continue Reading