{"operation":"document","citation":"CPF 42022029NOA","title":"GENESIS OFFSHORE HOLDINGS, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.308, 195.452(g)(1)(i), 195.452(g)(2), 195.452(g)(3), 195.452(g)(4), 195.452(h)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022029noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022029noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022029noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42022029NOA","body":"Notice of Amendment involving GENESIS OFFSHORE HOLDINGS, LLC. PHMSA's enforcement data identifies the cited regulations as 195.308,  195.452(g)(1)(i),  195.452(g)(2),  195.452(g)(3),  195.452(g)(4),  195.452(h)(2). The case was opened on 2022-04-08 and is reported as closed as of 2022-09-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42022029NOA_Closure Letter_09022022 (21-199241)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022029NOA/42022029NOA_Closure%20Letter_09022022%20(21-199241)_text.pdf\n\n42022029NOA_Closure Letter_09022022_(21-199241).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022029NOA/42022029NOA_Closure%20Letter_09022022_(21-199241).pdf\n\n42022029NOA_Notice of Amendment_04082022_(21-199241).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022029NOA/42022029NOA_Notice%20of%20Amendment_04082022_(21-199241).pdf\n\n42022029NOA_Notice of Amendment_04082022_(21-199241)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022029NOA/42022029NOA_Notice%20of%20Amendment_04082022_(21-199241)_text.pdf\n\n42022029NOA_Operator Response to Notice_05022022_(21-199241).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022029NOA/42022029NOA_Operator%20Response%20to%20Notice_05022022_(21-199241).pdf\n\n42022029NOA_Notice of Amendment_04082022_(21-199241)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nApril 8, 2022\nJeffrey W. Gifford\nVice President\nGenesis Offshore Holdings, LLC\n919 Milam Street, Suite 2100\nHouston, Texas 77002\nCPF 4-2022-029-NOA\nDear Mr. Gifford:\nFrom March 3, 2021 to October 28, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Genesis Offshore Holdings, LLC’s (Genesis) procedures for construction, integrity\nmanagement, operations, and maintenance in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within the\ncompany’s procedures, as described below:\n1. § 195.308 Testing of tie-ins.\nPipe associated with tie-ins must be pressure tested, either with the section to be tied\nin or separately.\nGenesis’ written procedure Engineering Standards and Specifications, STD.4507, Pipeline\nHydrostatic Testing (Date: 8/2020), is inadequate because it does not address testing of pipe\nassociated with tie-ins, either with the section of pipe to be tied-in or separately in accordance\nwith § 195.308.\nGenesis must amend its written Engineering Standards and Specifications, STD.4507, Pipeline\nHydrostatic Testing procedure to ensure that pipe associated with tie-ins is pressure tested,\neither with the section of pipe to be tied-in or separately.\n\n\n\n2. § 195.452 Pipeline integrity management in high consequence areas\n(a)…\n(g) What is an information analysis? In periodically evaluating the integrity of each\npipeline segment (see paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of its entire pipeline and the consequences\nof a possible failure along the pipeline. Operators must continue to comply with the\ndata integration elements specified in § 195.452(g) that were in effect on October 1,\n2018, until October 1, 2022. Operators must begin to integrate all the data elements\nspecified in this section starting October 1, 2020, with all attributes integrated by\nOctober 1, 2022. This analysis must:\n(1) Integrate information and attributes about the pipeline that include, but are\nnot limited to:\n(i) (ii) …\nPipe diameter, wall thickness, grade, and seam type;\n(2) Consider information critical to determining the potential for, and preventing,\ndamage due to excavation, including current and planned damage prevention\nactivities, and development or planned development along the pipeline;\n(3) Consider how a potential failure would affect high consequence areas, such as\nlocation of a water intake.\n(4) Identify spatial relationships among anomalous information (e.g., corrosion\ncoincident with foreign line crossings; evidence of pipeline damage where aerial\nphotography shows evidence of encroachment). Storing the information in a\ngeographic information system (GIS), alone, is not sufficient. An operator must\nanalyze for interrelationships among the data.\nGenesis’ written Integrity Management Program, IM Procedure 601L, Liquid-Information\nAnalysis Procedure, 1.1.2 (Revision Date: 8/14/2020) is inadequate because it allows for the\ninformation analysis to be performed up to and including the day of a scheduled assessment.\nThe procedure states, “The information analysis shall be performed within a two (2) year\ninformation analysis period measured prior to the date of scheduled reassessment.”\nGenesis must amend section 1.1.2 of its IM Procedure 601L to establish an interval for\nperforming information analysis that allows for information analysis to be completed and\nincorporated into an assessment plan before the scheduled assessment. Specifically, the\nestablished interval must allow for any changes to be made to an assessment plan due to new\ndata gathered during the information analysis.\n2\n\n\n\n3. § 195.452 Pipeline integrity management in high consequence areas.\n(a)…\n(h) What actions must an operator take to address integrity issues?\n(1)…\n(2) Discovery of condition. Discovery of a condition occurs when an operator has\nadequate information to determine that a condition presenting a potential threat\nto the integrity of the pipeline exists. An operator must promptly, but no later\nthan 180 days after an assessment, obtain sufficient information about a condition\nto make that determination, unless the operator can demonstrate the 180-day\ninterval is impracticable. If the operator believes that 180 days are impracticable\nto make a determination about a condition found during an assessment, the\npipeline operator must notify PHMSA in accordance with paragraph (m) of this\nsection and provide an expected date when adequate information will become\navailable.\nGenesis’ written Integrity Management Program, IM Procedure 402, ILI Report Analysis\nProcedure for HCAs (Revision Date: 8/14/2020) is inadequate because the procedure does not\naddress the requirement prescribed in §195.452(h)(2). Specifically, section 2.2.14 fails to\nprovide for provisions to notify PHMSA when the operator believes 180 days are impractical\nto determine a condition found during an assessment and provide an expected date when\nadequate information will become available. Genesis’ procedure states, “Discovery of the\nconditions listed in an ILI Assessment Report occurs on the date that ILI Coordinator has\ndetermined the report to be valid. Discovery occurs no later than 180 days after completion of\nan assessment unless it can be demonstrated that the 180-day period is impracticable. If\ndiscovery is to occur later than 180 days after completion of an assessment, this deviation shall\nbe documented”.\nGenesis must amend its written Integrity Management Program, IM Procedure 402, ILI Report\nAnalysis Procedure for HCAs, 2.2.14 to include the requirement to notify PHMSA and provide\nan expected date when adequate information will become available if the operator believes 180\ndays are impractical to make a determination about a condition found during an assessment.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\n3\n\n\n\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 90 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Genesis maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Mary McDaniel, Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2022-029-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: John Jewett, Manager – Regulatory Compliance, Genesis, John.jewett@genlp.com\n4\n\n42022029NOA_Closure Letter_09022022 (21-199241)_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 02, 2022\nJeffrey W. Gifford\nVice President\nGenesis Offshore Holdings, LLC\n919 Milam Street, Suite 2100\nHouston, Texas 77002\nCPF 4-2022-029-NOA\nDear Mr. Gifford:\nFrom March 3, 2021, to October 28, 2021, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code\n(U.S.C), inspected Genesis Offshore Holdings, LLC’s (Genesis) procedures for construction,\nintegrity management, operations and maintenance in Houston, Texas. As a result of the\ninspection, Genesis was issued a Notice of Amendment on April 8, 2022, which proposed\namendments to Genesis’ procedures.\nGenesis submitted its amended and supplementary procedures on May 2, 2022, and August 24,\n2022, respectively. PHMSA staff reviewed these procedures, and it appears that the inadequacies\noutlined in this Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: John Jewett, Manager – Regulatory Compliance, Genesis, John.jewett@genlp.com\n\n42022029NOA_Closure Letter_09022022_(21-199241).pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n8701 S. Gessner, Suite 630\nHouston TX 77074\nSeptember 02, 2022\nJeffrey W. Gifford\nVice President\nGenesis Offshore Holdings, LLC\n919 Milam Street, Suite 2100\nHouston, Texas 77002\nCPF 4-2022-029-NOA\nDear Mr. Gifford:\nFrom March 3, 2021, to October 28, 2021, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code\n(U.S.C), inspected Genesis Offshore Holdings, LLC’s (Genesis) procedures for construction,\nintegrity management, operations and maintenance in Houston, Texas. As a result of the\ninspection, Genesis was issued a Notice of Amendment on April 8, 2022, which proposed\namendments to Genesis’ procedures.\nGenesis submitted its amended and supplementary procedures on May 2, 2022, and August 24,\n2022, respectively. PHMSA staff reviewed these procedures, and it appears that the inadequacies\noutlined in this Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: John Jewett, Manager – Regulatory Compliance, Genesis, John.jewett@genlp.com","truncated":false,"body_characters":12692}