Frequently-Asked Question FAQ #76

FAQ-76: What is an IM program?

Question: What is an Integrity Management Program?

Answer: An Integrity Management Program begins with a written framework describing how the elements which follow will be implemented. Elements required to be part of the program (and the paragraphs of the rule in which they are described) are:

• An identification of all high consequence areas (192.905).
• A baseline assessment plan (192.919 and 192.921).
• An identification of threats to each covered pipeline segment, which must include data integration and a risk assessment. An operator must use the threat identification and risk assessment to prioritize covered segments for assessment (192.917) and to evaluate the merits of additional preventive and mitigative measures (192.935) for each covered segment.
• A direct assessment plan, if applicable (192.923, and depending on the threat assessed, 192.925, 192.927, or 192.929).
• Provisions for remediating conditions found during an integrity assessment (192.933).
• A process for continual evaluation and assessment (192.937).
• If applicable, a plan for confirmatory direct assessment (192.931).
• Provisions for adding preventive and mitigative measures to protect the high consequence area (192.935).
• A performance plan as outlined in ASME/ANSI B31.8S, Section 9 that includes performance measures meeting the requirements of 192.943.
• Record keeping provisions (192.947).
• A management of change process as outlined in ASME/ANSI B31.8S, Section 11.
• A quality assurance process as outlined in ASME/ANSI B31.8S, Section 12.
• A communication plan that includes the elements of ASME/ANSI B31.8S, Section 10, and that includes procedures for addressing safety concerns raised by OPS and a State or local pipeline safety authority when a covered segment is located in a State where OPS has an interstate agent agreement.
• Procedures for providing (when requested), by electronic or other means, a copy of the operator’s risk analysis or integrity management program to OPS and a State or local pipeline safety authority when a covered segment is located in a State where OPS has an interstate agent agreement.
• Procedures for ensuring that each integrity assessment is being conducted in a manner that minimizes environmental and safety risks.
• A process for identification and assessment of newly-identified high consequence areas. (192.905 and 192.921.)

A fully-developed program involves complete documentation of how each element noted above will be performed.