Pipeline Safety Update - Issue No. 137

May 2, 2018

TSA Updates Pipeline Security Guidelines

The Transportation Security Administration (TSA) has released updated Pipeline Security Guidelines recommending measures to protect pipeline cyber assets.  The updated guidelines revise incident response protocols, focus on operational technology systems, and recommend consideration of the approach of the National Institute of Standards and Technology.  Van Ness Feldman’s recent alert, prepared by our Cybersecurity team, provides additional detail and analysis.

PHMSA Rulemakings Update.  The tables below summarize the status of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) pending pipeline safety rulemaking initiatives, as reflected in the Department of Transportation’s April Significant Rulemaking Report and the Unified Regulatory Agenda, released by the Office of Management & Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) in Fall 2017.  The Unified Regulatory Agenda appears in two principal parts:  Current Agenda Agency Regulatory Entries for Active Actions and Current Long Term Actions.  New information appears in bold.

Pending Final Rules


DOT Estimated Submission to OMB

DOT Estimated Publication

OIRA Estimated Publication 

Enhanced Emergency Order Procedures   Not Listed  Not Listed January 2018
Plastic Pipe Rule
May 16, 2018
August 28, 2018
August 2018
Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments  December 4, 2018 March 14, 2019 Not Listed 
Safety of Gas Transmission Pipelines, Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments   March 4, 2019 June 12, 2019 Not Listed 
Safety of Gas Gathering Pipelines   May 2, 2019 August 14, 2019 Not Listed
Safety of Hazardous Liquid Pipelines
June 8, 2018 September 19, 2018 April 2018
Underground Natural Gas Storage Facilities   Not Listed September 26, 2018 January 2018


Pending Notices of Proposed Rulemaking (NPRM) & Advanced Notices of Proposed Rulemakings (ANPRM)


DOT Estimated Submission to OMB

DOT Estimated Publication 

OIRA Estimated Publication 

ANPRM: Class Location Requirements   May 8, 2018 June 1, 2018 April 2018
NPRM: Standards Update Rule - 2015 and Beyond
Not listed Not listed June 2018
NPRM: Valve Installation and Minimum Rupture Detection Standards  Not Listed Not Listed April 2018


Under Executive Order (EO) 12866, OMB reviews proposed significant rules to ensure they are consistent with applicable law, the President’s priorities, and the principles set forth in the EO, and to ensure the proposals do not conflict with another agency’s policies or actions. OMB also analyzes the cost-benefit analyses in support of the proposals. The EO sets out deadlines for OMB evaluation, but review periods are often extended.


PHMSA provides additional time for public comment on renewal of information collection.  On April 23, PHMSA issued a notice of an additional 30-day comments period regarding the renewal of an information collection (OMB control number 2137-0049) that requires owners and operators of gas pipelines to maintain records, make reports and provide information to the Secretary of Transportation at the Secretary’s request.  The existing information collection expires April 30.  Comments are due May 23.


GAO releases report presenting views on pipeline odorization.   On April 18, the Government Accountability Office (GAO) released a report summarizing views of various stakeholders, including officials of PHMSA and the National Transportation Safety Board, state officials, and other stakeholders on the odorization of gas pipelines.  The report, entitled Gas Pipeline Safety:  Stakeholders’ and Officials’ Views on Federal Odorizing Requirements, states that general agreement exists that distribution pipelines should be odorized because of their proximity to populated areas, and that the majority of state officials and stakeholder did not view odorizing gas gathering pipelines as necessary because of technical challenges and the primary location of these types lines in rural areas.  With respect to transmission pipelines, stakeholders disagreed on whether odorization improves public safety, with some stakeholders stating that such lines tend to operate at pressures that cause ruptures rather than leaks, thereby diminishing the effectiveness of odorization, and because odorization can adversely affect certain industrial processes.


API and AOPL release report on pipeline safety.  The American Petroleum Institute (API) and Association of Oil Pipe Lines (AOPL) released their 2018 “Pipeline Safety Excellence Performance Report” finding that total pipeline safety incidents affecting people or the environment dropped 19% from 2013-2017, and that total incidents increased 3% over 5 years.  Incidents caused by integrity management failures fell 35 percent; and incidents caused by operations or maintenance failures fell 24 percent.



HB 1419.  The Preventing Explosions, Nondisclosures, and Toxic Releases Act, introduced April 23, would require the Colorado Oil and Gas Conservation Commission to adopt rules to ensure wellhead integrity of oil and gas production wells and to address their permitting, construction and closure.  Each oil and gas operator would be required to provide electronic notice of the location of each flow line and gathering pipeline to each local government within whose jurisdiction the subsurface pipeline is located.  Operators also would be required to share development plans with municipalities and counties within whose jurisdictions the proposed operation would occur.  The bill passed the Colorado House of Representatives on April 30. 


Senate Resolution 1534 would direct the Illinois Department of Natural Resources to compile a report reviewing the current state gas pipeline regulations, including those applicable to gas extraction and underground gas storage, and recommend regulatory changes to improve public safety.  The report is to be transmitted to the Illinois legislature no later than December 31.  The proposed resolution has been referred to the Senate Environment and Conservation Committee.

To download a full text PDF, which includes Dates of Interest, upcoming PHMSA State Seminars, and State Specific Association Meetings, please click here.

Update Authors

Susan A. Olenchuk
Washington D.C.
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Bryn S. Karaus
Washington D.C.
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Related Professionals

Related Services & Industries

Natural Gas & Oil Pipelines

Dates of Interest

January 2021
21-22 AGA Overview of Pipeline Safety Reauthorization, Virtual
February 2021
2-3 SGA DOT 192 Compliance Gas Pipeline Operators, Virtual Workshop
4 Comments due on Midstream Processing Facilities FAQs
16 Comments due OQ FAQs
16 Comments due on Proposed Revised Forms
24-25 Pipeline Pigging & Integrity Management Conference, Virtual
March 2021
1-4 AGA Gas Piping Technology Committee Meeting, Virtual
4 Common Ground Alliance Conference & Expo, Orlando, FL
16 Comments due Batch-2 FAQs for Gas Transmission Rule
16 Comments due NPRM to Update of Regulatory References to Technical Standards
16-17 Pipeline Safety Regulatory Compliance, Virtual
23-24 SGA Pipeline Integrity Management, Virtual
April 2021
5-8 MEA Gas Ops, Virtual Forum
19-22 GTI Gas Distribution Operations, Webinar
20-22 API 2021 Pipeline Conference, Savannah, GA
27-28 SGA DOT 192 Compliance for Natural Gas Pipeline Operators, Virtual
28-29 World Pipeline Integrity 2021, Virtual
May 2021
10-13 Pipeline Risk Management Forum, Houston, TX

State-Specific Association Meetings

February 2021
2 Comments due VA Proposed Rule: Professional Engineering Stamps for Gas Projects
22 Comments due MPUC Rulemaking on Natural Gas and LNG Facility Operators