PHMSA Gas Integrity Management
Time: 11/23/2009 08:09 PM

Frequently-Asked Question FAQ #140

FAQ-140: Level of Detail in IM Frameworks

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Question: What level of detail does OPS expect to see in initial IM frameworks for each of the required program elements?

Answer: The level of detail in the framework will vary depending on the level of maturity of each program element. In general, OPS expects that elements that must be implemented early will have considerable detail. This includes identification of all high consequence areas, threat identification, and baseline assessment plans. The description in the framework of elements that will be implemented later may be more sketchy. These include a continual process for evaluation and assessment, process for adding preventive and mitigative measures, and plans for confirmatory direct assessment. OPS would expect a reasonably complete description of the elements that relate to managing the IM program, e.g., quality assurance, management of change, and record keeping, although the IM program descriptions of these elements may become more detailed as experience is gained.

OPS would find unacceptable a situation in which a program element was being actively implemented but little or no description of that element is included in the IM framework/program. Program elements should be thought out, documented, and receive the internal approvals the operator considers necessary before they are implemented.

These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of the pipeline integrity management rules. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing integrity management regulations and standards. Requests for informal interpretations regarding the applicability of one or more of the pipeline integrity management rules to a specific situation may be submitted to PHMSA in accordance with 49 C.F.R. § 190.11.
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