In this webinar, RCP will provide an overview of the requirements found within PHMSA’s recent rule update, commonly referred to as “RIN2, Gas Mega Rule” published on August 4, 2022. This amendment is related to the Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments rulemaking issued on October 1, 2019. The amendments include clarification of integrity management requirements, codification of the management of the change process, revision to corrosion control requirements, an inspection of pipelines after extreme weather events, adjusting high consequence area repair requirements, and adding new requirements for non-high consequence area segments. Participants will come away with an understanding of the new requirements and what they need to do to prepare for implementation.

Date: October 17, 2022 (Monday): 1-2 p.m. CST

Really Cool People can Click here to register for the free webinar.

This webinar from the Pipeline Association for Public Awareness (PAPA) was designed to help public officials learn how online pipeline mapping tools can help promote the safe development of their community and aid in emergency response planning. The webinar is applicable for emergency managers, emergency officials, first responders, land planners, public officials, developers and permitters.

The webinar was held on Tuesday, October 11 – prior to us publishing this newsletter. Visit the PAPA website for more information on future webinars.

Check out our latest eLearning course on Fundamentals of Pressure Testing at the Pipeline Safety Institute. In this course, you will be guided through the processes of designing, planning, executing, and evaluating/validating a pressure test. This course is designed for attendees from a variety of backgrounds including engineers, field techs, and other pipeline professionals. Certificates of completion are available upon successful completion of the knowledge test at the end of the course.

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 August 2022, PHMSA issued 8 WLs, 7 NOAs, 1 NOPSO, and 7 NOPVs accompanied by $118,200 in proposed fines. Significant proposed fines were attributed to the following code sections:

• $12,000 – 49 CFR 195.302(a) – Hydrostatic Tests
• $15,500 – 49 CFR 192.807(a)(4) – Operator Qualification Recordkeeping
• $45,200 – 49 CFR 191.23(a)(5) – Safety-related Condition Reports
• $20,700 – 49 CFR 192.465(c) – External Corrosion Control Monitoring
• $24,800 – 49 CFR 192.465(d) – External Corrosion Control Monitoring

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.