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DOT PIPELINE COMPLIANCE NEWS

JANUARY 2022 ISSUE

IN THIS ISSUE

 1. RCP Welcomes Dewitt Burdeaux, Senior Executive Consultant
 2. Interim Final Rule: Unusually Sensitive Areas for the Great Lakes, Coastal
    Beaches and Certain Coastal Waters
 3. PHMSA 2022 Drug & Alcohol Testing Rate
 4. The Enforcement Corner
 5. Client Feedback

--------------------------------------------------------------------------------


RCP WELCOMES DEWITT BURDEAUX, SENIOR EXECUTIVE CONSULTANT

After the 27 years of trying, RCP has finally hired a Cajun whose name ends in
X.  RCP is pleased to announce that Dewitt Burdeaux has joined our team. Mr.
Burdeaux has over 40 years of experience in pipeline safety compliance, training
and consulting. With a tenure of nearly twenty years with PHMSA, Mr. Burdeaux
served as project manager or core team member for several PHMSA major rulemaking
initiatives, including DIMP and Gas Gathering.

He has served in an advisory role to pipeline operating companies regarding
design, construction, testing, operations, maintenance and integrity management
programs for hazardous liquids, gas gathering and transmission pipeline systems.

Please join us in welcoming Dewitt to the RCP team.

--------------------------------------------------------------------------------


INTERIM FINAL RULE: UNUSUALLY SENSITIVE AREAS FOR THE GREAT LAKES, COASTAL
BEACHES AND CERTAIN COASTAL WATERS


[DOCKET NO. PHMSA–2017–0152; AMDT. NO. 195–104]

PHMSA published an Interim Final Rule (IFR) effective 2/25/2022 that defines
“certain coastal waters” and “coastal beaches” and includes both in the
definition of Unusually Sensitive Areas (USAs) for hazardous liquid pipelines.
These areas include the Great Lakes and the territorial seas (12 miles from
shore) all the way up to the influence of tidal waters (perhaps many miles
inland). Tens of thousands of miles of shoreline are now defined as USAs,
including many locations that are far from the coastline.

These definitions will have wide-reaching impacts because USAs are included in
the definition of High Consequence Areas (HCAs) for hazardous liquid pipelines,
which are used to determine the applicability of hazardous liquid Integrity
Management Program (IMP) requirements. Expansion of USAs leads directly to the
expansion of the miles of pipe included in IMPs. Also, the proximity of a
pipeline to a USA is used to determine regulatory jurisdiction for hazardous
liquid gathering lines. Therefore, the expansion of USAs causes more gathering
pipelines to be jurisdictional (or have a higher level of jurisdiction). The
types of pipelines impacted, and the impacts, are summarized below.

Onshore* Rural Hazardous Liquid Gathering Lines

The newly defined USAs will result in additional pipelines being classified as
regulated rural gathering lines. An onshore rural hazardous liquid gathering
line is subject to §195.11 if the pipeline:

 * has a nominal diameter from 6-⅝ inches to 8-⅝ inches;
 * has a stress level greater than 20 percent of the specified minimum yield
   strength (or if the stress level is unknown, or for non-steel pipelines, a
   pressure less than or equal to 125 psig); and
 * is located within ¼ mile of a USA.

Pursuant to §195.11(c), an operator must comply with §195.11(b)(2)-(11) within 6
months from the date that a new USA has been identified (i.e., from 2/25/2022),
except for the requirements for corrosion control which are subject to the
compliance timelines in Part 195, subpart H.

An operator of a regulated rural hazardous liquid gathering line must:

 * comply with reporting requirements in subpart B of Part 195;
 * establish a maximum operating pressure of the pipeline in accordance with
   §195.406;
 * install and maintain line markers in accordance with §195.410;
 * establish and carry out a public education program in accordance with
   §195.440;
 * establish and carry out a damage prevention program in accordance with
   §195.442;
 * comply with corrosion control requirements in subpart H;
 * establish and carry out a program to identify internal corrosion in
   accordance with §195.11(b)(10); and
 * comply with operator qualification program requirements in accordance with
   subpart G of Part 195 and §195.505.

A new or replaced regulated rural hazardous liquid gathering line must also
comply with the initial design, installation, construction inspection, and
testing requirements in Part 195, unless that pipeline is being converted to
service under §195.5.

Rural Low-Stress Hazardous Liquid Pipelines

Some Category 3 rural low-stress lines may become Categories 1 or 2 rural low
stress lines (i.e., within ½ mile of a new USA) and, therefore, would be subject
to hazardous liquid Integrity Management Program (IMP) requirements at
§195.452(a). Pursuant to §195.12(e), a Category 3 rural low-stress line or any
other pipeline that becomes a Category 1 or Category 2 rural low-stress line
must comply with the IMP requirements within 12 months following the date the
USA is identified (i.e., from 2/25/2022).

The Part 195 requirements applicable to low-stress pipelines located in rural
areas depend on the pipeline’s proximity to a USA. Section 195.12 defines a
low-stress rural pipeline as a line located in a rural area and having a maximum
operating pressure corresponding to a stress level of 20 percent or less of the
specified minimum yield strength (or if the stress level is unknown, or for
non-steel pipelines, a pressure less than or equal to 125 psig). A rural
low-stress line that is located within ½ mile of a USA (or alternatively, that
could affect an HCA as determined in §195.452(a)) is a Category 1 or Category 2
rural low-stress line that must comply with all of the safety requirements in
Part 195. Other rural low-stress pipelines not within ½ mile of a USA are
Category 3 lines that must comply with all the requirements of Part 195 except
the IMP requirements in §195.452.

All Hazardous Liquid Pipelines

There will be many more miles of hazardous liquid pipelines that “could affect”
an HCA because USAs are HCAs. Thus, the expansion of USAs likewise expands HCAs.
These newly covered pipeline miles must be added to a Baseline Assessment plan
within 1 year of 2/25/2022, and have a baseline assessment within 5 years. They
must have a means to detect leaks per 195.452(i)(3).

*Do not be confused by the word “onshore.” Many pipelines are underwater in
coastal areas and still considered to be “onshore.” “Onshore” includes any
pipeline that is not “beyond the line of ordinary low water along that portion
of the coast of the United States that is in direct contact with the open seas
and beyond the line marking the seaward limit of inland waters.” As the IFR
states, “A pipeline could be located within certain coastal waters and be either
‘onshore’ or ‘offshore’ under §§192.3 and 195.2.”

--------------------------------------------------------------------------------


PHMSA 2022 DRUG & ALCOHOL TESTING RATE


[DOCKET NO. DOCKET NO. PHMSA-2021-0107]

PHMSA has determined the minimum random drug-testing rate for covered employees
will remain at 50 percent during calendar year 2022.  Operators are reminded
that drug and alcohol testing information must be submitted for contractors who
are performing or are ready to perform covered functions.  For calendar year
2021 reporting, the username and password for the Drug and Alcohol Management
Information System will be available in the PHMSA Portal.  The effective date of
this notice is January 1, 2022, through December 31, 2022.

For a pdf copy of the notice with more detailed information, contact Jessica
Foley.

--------------------------------------------------------------------------------


THE ENFORCEMENT CORNER

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating
where PHMSA is putting its enforcement efforts and the fines they are proposing
for various types of violations.

In November 2021, PHMSA issued 5 NOAs, 12 NOPVs, and 6 WLs accompanied by
$1,323,347 in proposed fines. Significant proposed fines were attributed to the
following code sections:

 * $6,900 – 49 CFR 195.452(h)(4)(iii)(E) – 180-day Conditions
 * $27,900 – 49 CFR 195.403(c) – Emergency Response Training
 * $46,600 – 49 CFR 195.452(b)(1) – IM Program in HCAs
 * $80,000 – 49 CFR 195.452(l)(ii) – IM Program in HCAs
 * $67,700 – 49 CFR 195.452(f) – IM Program in HCAs
 * $61,100 – 49 CFR 195. 452(b)(5) – IM Program in HCAs
 * $209,700 – 49 CFR 195.406(b) – Maximum Operating Pressure
 * $19,300 – 49 CFR 195.573(e) – Monitoring External Corrosion
 * $115,500 – 49 CFR 195.573(a)(1) – Monitoring External Corrosion
 * $40,000 – 49 CFR 195.573(c) – Monitoring External Corrosion
 * $36,200 – 49 CFR 195.52(b) – NRC Reporting
 * $218,647 – 49 CFR 195. 402(c)(11) – O&M Procedures
 * $276,400 – 49 CFR 195. 402(c)(13) – O&M Procedures
 * $61,100 – 49 CFR 195.402(a) – O&M Procedures
 * $38,000 – 49 CFR 192.805(b) – Operator Qualification Plan
 * $19,000 – 49 CFR 195.440(c) – Public Awareness

Please note:

 1. Pipeline operators may disagree in whole or in part with each proposed
    violation cited by PHMSA. 
 2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an
    enforcement action becomes final.
 3. A Corrective Action Order (CAO) usually addresses urgent situations arising
    out of an accident, spill, or other significant, immediate, or imminent
    safety or environmental concern.
 4. A Notice of Amendment (NOA) is frequently a result of a difference of
    opinion regarding written procedure requirements.
 5. A Notice of Proposed Safety Order (NOPSO) addresses pipeline integrity risks
    that may not constitute a hazardous facility requiring immediate corrective
    action (see Corrective Action Order described above),but do need to be
    addressed over time.
 6. A Notice of Probable Violation (NOPV) is not proof that a violation actually
    occurred.
 7. A Proposed Compliance Order (PCO) frequently documents actions the pipeline
    operator already planned to do.
 8. Warning Letter (WL) is an official notice by PHMSA that an operator needs to
    make improvements but that no further enforcement is proposed for those
    findings at this time.

RCP maintains a detailed database of all PHMSA enforcement actions dating back
to 2007 and is routinely asked for data analysis of various enforcement actions.
For more information on how RCP can assist with enforcement action data analysis
services, contact Jessica Foley.

Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course? 
RCP maintains a detailed database of all PHMSA enforcement actions and their
resolution which enables us to compare and contrast individual enforcement
actions to nationwide actions and trends.  We can help put things into context
to ensure an effective reply for each citation.  For more information on how RCP
can assist with enforcement action data analysis services, contact Jessica
Foley.

--------------------------------------------------------------------------------


CLIENT FEEDBACK

RCP has a tradition of creating and sustaining trusted partnerships with the
companies we serve. This has translated into long-term relationships that are
based not only on the quality and scope of the work we provide, but also on the
manner in which we provide it. We routinely hear from our clients with positive
feedback like this quote below:

“Thanks everyone for all the help in making the training so smooth. I have
received extremely positive feedback from my team regarding both the content and
the format, and you gave us a lot to think about with regards to potential gaps
within our programs.”

We would welcome the opportunity to discuss our services with you.

Sincerely,


W. R. (Bill) Byrd, PE
President
RCP Inc.







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RCP Inc.
801 Louisiana Street, Suite 200
Houston, TX 77002

(713) 655-8080

info@rcp.com


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 * Home
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 * What We Do
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     * Operations & Maintenance
     * Control Room Management
     * Facility Response Plans and Integrated Contingency Plans
     * Operator Qualifications
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     * Public Awareness
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     * Underwater Inspection Procedures
     * PSM/Risk Management Plan
     * Spill Prevention Countermeasures & Control
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     * Expert Witness
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     * Leak Detection Capabilities Evaluation
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     * Root Cause Failure Analysis
     * Engineering Specifications
   * Integrity Management
     * Risk Management
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     * ILI Data Analysis
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