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Pipeline Law

Category Archives: Reporting Obligations

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Underground Natural Gas Storage Interim Final Rule Issued

Posted in Administrative Rulemaking, Construction & Design, Natural Gas, Operation & Maintenance, PHMSA, Pipeline Safety Act, Reporting Obligations
PHMSA has issued an interim final rule (IFR) to establish – for the first time ever – minimum federal standards for underground natural gas storage facilities. The IFR imposes significant new requirements in a short timeframe for “downhole facilities,” including wells, wellbore tubing and casings at underground natural gas storage facilities.… 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 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

PHMSA Issues Notice of Random Drug Testing Annual Percentage Rate for Calendar Year 2015

Posted in PHMSA, Reporting Obligations
PHMSA regulations require operators to perform random drug testing on a certain percentage of their “covered employees” (i.e. employees, contractors, and contractor employees who perform regulated operations, maintenance, or emergency response functions on a pipeline or LNG facility, 49 C.F.R. Part 199.3).  49 C.F.R. Part 199.105(c).  The Agency publishes the minimum percentage of covered employees… 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

Extension of Comment Period on Revisions to PHMSA Gas Reporting Forms

Posted in Administrative Rulemaking, PHMSA, Reporting Obligations
Additional proposed revisions to natural gas reporting forms signal that PHMSA continues to rely on this data to analyze operator performance metrics and inform future rulemakings.  By notice issued on November 27, 2013, the Agency responded to comments on revisions to several natural gas reporting forms that it proposed in June (see prior posting) and… Continue Reading

PHMSA Responds to Comments on Revised Reporting Forms for Hazardous Liquid Pipelines

Posted in Administrative Rulemaking, PHMSA, Reporting Obligations
As previously reported, on April 23, 2013, PHMSA proposed changes to the hazardous liquid operators' accident report (Form 7000-1) to require additional detail regarding "low consequence" releases (releases between 5 gallons and 5 barrels) and to revise instructions regarding spill and recovery volumes, time sequence, and NRC instructions.… Continue Reading

EPA Issues New Oil Tank Emission Standards and Deadlines

Posted in Administrative Rulemaking, Environmental, Reporting Obligations
EPA has established new deadlines and caps on volatile organic compound (VOC) emissions from storage tanks used in oil and natural gas production and transmission that have the potential to emit more than 6 tons of VOCs per year. The pre-publication version of the new rule, to be codified as amendments to 40 C.F.R. Part… Continue Reading

PHMSA Rules That Releases Must Be Reported Before They Are “Reportable”

Posted in Enforcement, Judicial/ Administrative Decisions, PHMSA, Pipeline Safety Act, Reporting Obligations
In a decision that has significance to hazardous liquid pipeline operators nationally, PHMSA has denied a Petition for Reconsideration of a matter involving an oil tank overflow incident at a Buckeye facility that occurred in 2005.  The oil was contained within a diked area, and promptly cleaned up.  The next day a state environmental official… Continue Reading

Statutory Deadlines for PHMSA Action

Posted in PHMSA, Pipeline Safety Act, Policy, Reporting Obligations
Several Congressional deadlines for PHMSA, under the Pipeline Safety Act amendments (PSA), effective on Jan. 3, 2012, are due.  By July 3, 2013, PHMSA was directed to: (1) evaluate whether to expand integrity management requirements beyond high consequence areas (HCAs) and whether this may mitigate the need for class location requirements for gas transmission lines… Continue Reading

PHMSA Requests Comments on Revised Reporting Forms for Gas Distribution Pipelines

Posted in Administrative Rulemaking, PHMSA, Reporting Obligations
On February 13, 2013, PHMSA published a notice of its intent to revise the gas distribution annual report (PHMSA F7100.1–1). PHMSA received comments in response to that notice from the American Gas Association and the American Public Gas Association.  In today’s notice, PHMSA responds to the comments by: (a) revising Part A, Section 7 of… Continue Reading

PHMSA Requests Comments on Revised Reporting Forms for Hazardous Liquid Pipelines

Posted in Administrative Rulemaking, PHMSA, Reporting Obligations
PHMSA intends to revise Form 7000-1 (Hazardous Liquid Accident Report) to collect more information for smaller spills, require additional fields, and revise the form instructions. PHMSA notes that releases between five gallons and five barrels, and/or involving property damage less than or equal to $50,000 constituted 47% of reported releases in 2011 and 2012. Currently,… Continue Reading