In June 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a warning letter to Dakota Gasification Company (DGC), highlighting critical pipeline safety compliance issues. Here are the key points:
Key Compliance Issues
Public Awareness Program Evaluation (49 CFR § 195.440)
DGC failed to evaluate the effectiveness of their public awareness program by not comparing survey responses over time to identify trends or behavior changes.
Preventive and Mitigative Measures (PMMs) (49 CFR § 195.452(i)(1))
The company did not implement identified PMMs, specifically alternating current mitigation in a high consequence area.
Documentation of Decision-Making (49 CFR § 195.452(l)(1)(ii))
Insufficient documentation was provided to justify decisions regarding PMMs for multiple high consequence areas.
Tips to Prevent Future Issues
Nathan suggests the following tips to enhance pipeline safety compliance:
- Implement robust tracking systems and track survey responses over multiple years to identify trends. Consider using machine learning and AI solutions.
- Establish clear timelines, hold all involved accountable, and ensure timely implementation of identified PMMs.
- Capture the rationale behind all integrity management decisions by developing a comprehensive documentation process. Remember the old saying... if you didn't document it, it didn't happen.
- Conduct regular internal and third part internal audits to ensure compliance with regulations and identify gaps before official inspections.
- Invest in site specific / task specific training programs and keep staff updated on evolving regulatory requirements and best practices.
Potential Fines
While no penalties were assessed in this case, non-compliance can lead to significant financial risks. PHMSA can impose civil penalties up to $266,015 per violation per day, with a maximum of $2,660,135 for a related series of violations. For LNG facilities, an additional penalty of up to $97,179 per violation may apply.
Maintaining rigorous compliance programs is crucial to enhancing pipeline safety and minimizing regulatory risks.
Schedule a time with Nathan to discuss potential pipeline safety compliance items and ensure your organization stays ahead of compliance challenges. Let’s work together to enhance safety and minimize risks.