Susan A. Olenchuk




1050 Thomas Jefferson Street NW
Seventh Floor
Washington, DC 20007

Representative PHMSA Experience:

  • Counseling operators on compliance and interpretive questions relating to the application of PHMSA’s regulations and policies to real-life operational circumstances and business planning.
  • Assisting operators in validating MAOP and MOP and in interpreting these regulations in a range of nuanced operational circumstances.
  • Assisting trade association in drafting comments on a significant rulemaking that could have far-reaching impacts for operators of gas transmission and gathering pipelines; Assisting with outreach to FERC on potential impacts of proposed regulations on pipelines. 
  • Advising operators of liquids pipelines and gas distribution, transmission and gathering pipelines on PHMSA jurisdictional and regulatory classifications.
  • Representing and advising operators in enforcement proceedings before PHMSA and state regulatory agencies.  Recent success involved PHMSA’s withdrawal of an NOPV filed against a gas pipeline and successfully representing a crude oil pipeline in a PHMSA civil penalty case resulting in settlement and elimination of the civil penalty in exchange for an agreement to perform supplemental safety projects.
  • Conducting on-site, pre-audit reviews of compliance procedures and documents for liquid and gas pipelines preparing for PHMSA inspections, including integrated inspections.
  • Helping pipelines prepare and update written compliance procedures.
  • Advising operators on pipeline safety compliance issues in connection with the acquisition and sale of assets.
  • Assisting pipeline in obtaining special permits.
  • Providing training and CLE seminars to in-house legal staff and management regarding PHMSA jurisdiction, programs, and processes.
  • Assisting with post-incident response.

Representative FERC Experience:

  • Advising natural gas pipelines and customers in rate, tariff, certificate, and rulemaking proceedings.
  • Assisting interstate gas pipelines with pipeline FERC rate and abandonment implications of pipeline safety regulatory developments.
  • Counseling natural gas pipelines and LDCs on implementation and compliance issues arising under FERC’s affiliate Standards of Conduct and undue preference policies.
  • Counseling pipelines on jurisdictional issues associated with natural gas transportation and storage services provided under Section 311 of the NGPA.


Pipeline Records Verification: Compliance Questions for Operators

Pipeline and Gas Journal, Vol. 239 Issue 9

The Potential Impact of New Pipeline Safety Laws on PHMSA's Regulatory Initiatives

Pipeline and Gas Journal, Vol. 239 Issue 4

Pipeline Safety: Attorneys Ready for the Challenge

Pipeline & Gas Journal, Vol. 238 Issue 8

Hydro Licensing and the Endangered Species Act: Implications of FERC's Current Approach

Hydro Review
Recipient of the Author's Award as the No.1 ranked article by readers, Vol. 26 Issue 3

Report of the Judicial Review Committee

Energy Law Journal, Vol. 27 Issue 1

The Pipeline Safety Improvement Act of 2002

Energy Law Journal, co-authored with Theresa I. Zolet, Vol. 24 Issue 1


16th Annual Platts Gas Storage Outlook Conference

Panel Moderator, "The Future of Safety Regulation of Underground Natural Gas Storage Facilities"
Houston, TX

S&P Global Market Intelligence

Presenter, "Pipeline Safety Issues"
Washington, DC

The Basics of FERC Ratemaking for Interstate Pipelines

Instructor, "FERC Ratemaking Under the Natural Gas Act"
New Mexico State University
Albuquerque, NM

AGA 2016 Legal Forum

Presenter,"Pipeline Safety Act and the Impact of Proposed Regulations and New Legislation"
Asheville, NC

Energy Bar Association Annual Conference

Panelist, "Known Knowns and Known Unknowns: Sifting Through Regulatory Changes in the Gas Pipeline Industry"
Energy Bar Association
Washington, DC

2016 API Pipeline Conference

Moderator, "PHMSA Regulatory Agenda"
American Petroleum Institute
Carlsbad, CA

The Basics of Natural Gas Pipeline Ratemaking Course

Instructor, FERC Ratemaking under the Natural Gas Act
New Mexico State University - Center for Public Utilities
Albuquerque, NM

Shale Insight 2015

Panelist, "Pipeline Safety: Understanding Federal and State Regulatory Programs which affect Midstream Pipeline Operations"
Marcellus Shale Coalition
Philadelphia, PA

6th Annual Pipe Tech Americas Summit

Speaker, "Preparing Your Pipelines for IVP"
San Antonio, TX