Susan A. Olenchuk

Partner

202.298.1896

sam@vnf.com

Assistant

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.

Publications

Pipeline Records Verification: Compliance Questions for Operators

Pipeline and Gas Journal, Vol. 239 Issue 9
09/01/2012

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

Pipeline and Gas Journal, Vol. 239 Issue 4
04/01/2012

Pipeline Safety: Attorneys Ready for the Challenge

Pipeline & Gas Journal, Vol. 238 Issue 8
08/01/2011

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
06/01/2007

Report of the Judicial Review Committee

Energy Law Journal, Vol. 27 Issue 1
06/01/2006

The Pipeline Safety Improvement Act of 2002

Energy Law Journal, co-authored with Theresa I. Zolet, Vol. 24 Issue 1
02/01/2003

Presentations

S&P Global Market Intelligence

Presenter, "Pipeline Safety Issues"
Washington, DC
12/15/2016

The Basics of FERC Ratemaking for Interstate Pipelines

Instructor, "FERC Ratemaking Under the Natural Gas Act"
New Mexico State University
Albuquerque, NM
10/10/2016

AGA 2016 Legal Forum

Presenter,"Pipeline Safety Act and the Impact of Proposed Regulations and New Legislation"
Asheville, NC
07/10/2016

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
06/07/2016

2016 API Pipeline Conference

Moderator, "PHMSA Regulatory Agenda"
American Petroleum Institute
Carlsbad, CA
04/05/2016

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
10/11/2015

Shale Insight 2015

Panelist, "Pipeline Safety: Understanding Federal and State Regulatory Programs which affect Midstream Pipeline Operations"
Marcellus Shale Coalition
Philadelphia, PA
09/16/2015

6th Annual Pipe Tech Americas Summit

Speaker, "Preparing Your Pipelines for IVP"
San Antonio, TX
04/22/2015

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
10/12/2014