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.
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Recordkeeping
DOT Amends Emergency Order Affecting Crude Shipments by Rail
By Hunton & Williams LLP on
In response to concerns raised by shippers, on March 6, 2014, DOT amended its recent Emergency Order (see prior pipelinelaw alert) imposing certain testing and classification requirements on all persons who offer crude for transport by rail in the U.S. …
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DOT Emergency Order Affects Crude Shipments by Rail
By Hunton & Williams LLP on
In response to a string of recent accidents and subsequent investigations regarding the shipment of crude oil by rail, DOT issued an Emergency Order on February 25, 2014, requiring that crude shipped by rail be tested and properly classified prior to shipment. …
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Safety Alert Issued for Rail Transportation of Bakken Crude
By Hunton & Williams LLP on
On January 2, 2014, PHMSA issued a safety alert warning that Bakken crude oil may be more flammable than traditional heavy crude oil, and stressing the requirement that rail shipments be properly tested, characterized, degasified (if appropriate), and classified in appropriate packing group assignments. …
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Environmental Group Files Federal Complaint Against PHMSA To Produce Records
By Hunton & Williams LLP on
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…
PHMSA Issues Advisory Regarding MAOP/MOP Records Verification
By Hunton & Williams LLP on
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…
PHMSA Public Meeting on Recordkeeping and Risk Assessment
By Hunton & Williams LLP on
PHMSA held a public meeting on July 21, 2011 in Arlington, Virginia on “Improving Risk Assessment and Recordkeeping” due to recent pipeline incidents involving gaps in data and recordkeeping that have resulted in an increased focus on improving risk assessments.