Can an operator be cited for not complying with Appendix C?
The enforceability of Appendix C is addressed in the preamble to the final rule, as follows: An Appendix is guidance that is intended to give advice to operators on how to implement the requirements of the integrity management rule. An appendix does not have the same force as the regulation itself. An operator does not have to follow the guidance. However, if an operator incorporates parts of the Appendix into its integrity management program, an operator must then comply with those provisions. The guidance in Appendix C was also utilized in developing PHMSA Pipeline Safetys inspection protocols and will be consulted, as appropriate, during the inspection process.
