Pipeline Law

Pipeline Law

Tag Archives: IMP

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

PHMSA Seeks Comment on Whether IMP Expansion Mitigates the Need for Class Locations

Posted in Integrity Management, PHMSA, Pipeline Safety Act
As required by Section 5 of the amendments to the Pipeline Safety Act, PHMSA is seeking public comment on whether application of integrity management (IM) requirements beyond high consequence areas would mitigate the need for class location requirements for gas transmission pipelines.  78 F.R. 46560 (August 1, 2013).  PHMSA notes that the IM program provides additional… Continue Reading

PHMSA Extends Comment Period Regarding IMP Information Collection Requirements for Hazardous Liquid Pipeline Operators in HCAs

Posted in Integrity Management, PHMSA
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… Continue Reading

Senate Commerce Committee Field Hearing Regarding Pipeline Safety

Posted in Incident Response, Integrity Management, PHMSA, Policy, Reporting Obligations
In the wake of last month’s incident in Sissonville, West Virginia, Senator Rockefeller hosted a Senate Commerce Committee field hearing in Charleston, West Virginia to review pipeline safety. The witnesses included: (1) Sissonville resident Sue Bonham who lost her home; (2) NTSB chairman Deborah Hersman; (3) PHMSA Administrator Cynthia Quarterman; (4) Susan Fleming of GAO;… Continue Reading

GAO Releases Report Regarding Pipeline Operator Responses to Incidents in HCAs

Posted in Incident Response, Integrity Management, PHMSA, Reporting Obligations
As required by the 2012 amendments to the Pipeline Safety Act, the Government Accounting Office (GAO) released a report examining the ability of transmission pipeline operators to respond to releases in high consequence areas (HCAs). The report titled, “Better Data and Guidance Needed to Improve Pipeline Operator Incident Response,” concludes that (1) DOT should improve… Continue Reading

PHMSA Issues Advisory Bulletin Regarding IM Program Evaluation and Performance Metrics

Posted in Administrative Guidance, Integrity Management, PHMSA
In response to NTSB recommendations issued as a result of the San Bruno incident, PHMSA issued guidance on what it considers to be an effective integrity management (IM) performance evaluation process and program for measuring program effectiveness.  In addition, PHMSA IM inspections will emphasize review of operator IM performance metric methodology and confirm that operators… Continue Reading

PHMSA Administrator Speaks at AOPL-API Leadership Meeting

Posted in Integrity Management, PHMSA, Pipeline Safety Act
On November 8, 2012, PHMSA Administrator Cynthia Quarterman addressed the AOPL- API Leadership meeting in Washington, DC. Notably, Ms. Quarterman mentioned the following PHMSA priorities, among others, (1) draft Notice of Proposed Rulemaking for hazardous liquid pipelines (expected later this month); (2) review of leak detection and valve studies required by the 2012 amendments to… Continue Reading

PHMSA Extends Comment Period for Gas ANPRM to January 20, 2012

Posted in Administrative Rulemaking, Integrity Management, PHMSA
In response to industry requests for an extension of the comment period for PHMSA’s Advanced Notice of Proposed Rulemaking regarding the safety of natural gas transmission lines, the Agency has extended the comment period from December 2, 2011 to January 20, 2012. Click here to view the Federal Register Notice published November 16, 2011.  Click here to… Continue Reading