Pipeline Law

Pipeline Law

Category Archives: Recordkeeping

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Advisory on Deactivation of Integrity Management Threats

Posted in Administrative Guidance, Integrity Management, Natural Gas, PHMSA, Recordkeeping
A new Advisory on deactivation of threats for gas transmission lines was issued by PHMSA on March 15, 2017 (to be published in the March 16, 2017 Federal Register). Amidst uncertainty about the fate of various proposed and final rules issued by PHMSA and other federal agencies under the new Administration due to the Regulatory Freeze Executive Memorandum of January 20, 2017 and other executive orders, PHMSA’s issuance of this clarifying guidance regarding minimum criteria for deactivation of integrity threats is notable. … Continue Reading

Pipe Subject to Safety Regulations Until Formally Abandoned: PHMSA Advisory

Posted in Administrative Guidance, Enforcement, Natural Gas, Operation & Maintenance, PHMSA, Recordkeeping, Reporting Obligations
PHMSA issued an advisory to operators regarding the applicability of its safety regulations to idled, inactive and abandoned pipe. Congress directed PHMSA to issue such an advisory in the recent PIPES Act of 2016, in response to several high profile incidents involving idled pipe. … 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

PHMSA Proposes Amendments to Regulations to Address the Use of Plastic Pipe in Gas Service

Posted in Administrative Rulemaking, Construction & Design, Operation & Maintenance, PHMSA, Recordkeeping
PHMSA has published a Notice of Proposed Rulemaking (NPRM), proposing various changes to the natural gas pipeline safety regulations (49 C.F.R. Part 192) to address regulatory requirements involving plastic piping systems used in gas services. … Continue Reading

Proposed Expansion of NPMS Information Comment Period Extended

Posted in PHMSA, Public Awareness/ Community Relations, Recordkeeping, Reporting Obligations
PHMSA extended the comment period for its recent proposed expansion of information that operators must submit to the National Pipeline Mapping System (NPMS).  In response to an industry request for additional time, the Agency extended the comment period (which originally expired on September 29th) to December 1, 2014.… Continue Reading

Proposal to Substantially Expand Information Required in NPMS Submissions

Posted in PHMSA, Public Awareness/ Community Relations, Recordkeeping, Reporting Obligations
PHMSA recently proposed to significantly expand the information collected from operators through the National Pipeline Mapping System (NPMS). In the Agency’s notice and request for comment, PHMSA proposes to collect extensive information regarding pipeline attributes and extends reporting requirements to newly abandoned pipelines, regulated breakout tanks, and offshore gas gathering lines. … Continue Reading

Environmental Group Files Federal Complaint Against PHMSA To Produce Records

Posted in Environmental, Judicial/ Administrative Decisions, PHMSA, Recordkeeping
On April 10, 2013, Public Employees for Environmental Responsibility (PEER) filed suit against PHMSA in the US District Court for the District of Columbia, alleging that the Agency has failed to produce records and documents in response to requests made by PEER under the Freedom of Information Act (FOIA).  The group seeks copies of facility… Continue Reading

PHMSA Issues Advisory Regarding MAOP/MOP Records Verification

Posted in Administrative Guidance, PHMSA, Recordkeeping
In response to NTSB Recommendations and the 2012 amendments to the Pipeline Safety Act, PHMSA has issued guidance to operators to ensure that the MAOP and MOP of all liquid and gas pipeline segments are supported by records that are “traceable, verifiable and complete.” This Advisory marks the first time that PHMSA has issued guidance… Continue Reading