Jurisdictional Analysis | Integrity Solutions LTD

JURISDICTIONAL ANALYSIS

Our experts deliver jurisdiction applicability verification and justification.

When U.S. oil and gas pipeline operators need to verify the 49 CFR Part 192 or 49 CFR 195 jurisdiction applicability classifications and the boundary limits of their assets, they turn to us–the nationally recognized experts at Integrity Solutions®.

Since 1990, our senior consultants have authored and evaluated many key PHMSA interpretation letters for complex pipeline facilities and have completed over 100 jurisdiction analyses, following our rigorous process.

An operator’s first step towards compliance with hazardous liquid and gas pipeline safety regulations is to correctly delineate pipeline facility jurisdictional limits. Now, more than ever state and federal pipeline inspectors are looking inside the fence lines of refineries, stations, terminals, and plants that are connected to regulated pipelines and requiring operators to justify why these connected facilities are treated as exempt from regulation.

PHMSA has made significant modifications and interpretations related to 49 CFR 192 and 49 CFR 195 jurisdiction applicability criteria, often resulting in confusion and misapplication. In addition, the United States Coast Guard (USCG) has extended 33 CFR 154 jurisdiction limits on dock lines from first isolation valves in secondary containment to terminal storage tanks. Let our experts guide you through the regulatory jungle and provide you with a clear map, delineating which regulations are applicable to your diverse assets.

Expert Tip:
Maintaining jurisdictional pipeline facilities in full compliance with the latest regulations and following PHMSA or USCG guidance can be very costly. Performing periodic jurisdictional reviews can often identify opportunities to reduce the number of regulated pipeline facilities by removing them from jurisdiction where design and operations flexibility permits. We can show you how and where to do so.