Hazardous Liquid

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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 crude oil release from a Plains All American pipeline near Santa Barbara in May of 2015 used such thermal insulation, and the government’s investigation following that release prompted this Advisory from PHMSA.
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Continue Reading Advisory Bulletin Warns About Corrosion Under Insulation

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

PHMSA’s focus on shale activities extends beyond gathering and transmission lines; the Agency also regulates the transportation of hazardous materials, including crude, by rail.  In response to an unfortunate fatality derailment of a parked rail car containing Bakken crude oil that occurred over the summer in Quebec, and subsequent NTSB recommendations and industry petitions,…

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 60, Subpart 0000, can be accessed here, and will be effective immediately upon publication in the Federal Register. The rule generally applies to tanks involved in temporary storage along the oil and natural gas production and transmission process, before the liquids are moved to a pipeline, sold or disposed.
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Continue Reading EPA Issues New Oil Tank Emission Standards and Deadlines

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 requested removal of some additional soil, which caused response costs to slightly exceed the $50,000 reporting threshold established in PHMSA rules, at Parts 195.50 and 195.52.  The operator promptly reported the incident to the National Response Center (NRC) as soon as these reporting obligations were met.
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Continue Reading PHMSA Rules That Releases Must Be Reported Before They Are “Reportable”

As required under the Pipeline Safety Act amendments that became effective on January 3, 2012, PHMSA commissioned the National Research Council to study whether shipments of diluted bitumen differ sufficiently from shipments of other crude oils in such a way as to increase the likelihood of releases from transmission pipelines.  Significantly, the Committee’s final report,…

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,…

On April 15, 2013, the Vermont Natural Resources Board (Board) issued a jurisdictional opinion that Act 250, the State’s land use permitting statute, would apply to flow reversal projects for transport of Canadian tar sands oil.  The opinion was the result of a petition by several environmental groups seeking review of a possible reversal of…

On December 13, 2012, pursuant to an OMB information collection, PHMSA published a Federal Register notice soliciting comments from operators of hazardous liquid pipelines in HCAs regarding the information-collection requirements relative to the IMP provisions of 49 C.F.R. Part 195.452. Comments were invited on: (a) The need for the proposed collection of information for the…

The EPA Inspector General issued an audit report on February 21, 2013, analyzing oil and gas production emissions data contained in the 2008 National Emissions Inventory. The IG drew several conclusions from its review, including that the data is limited and incomplete for several key air pollutants, and that there are data gaps for some…