Protocol:
A.01 Program Requirements
Verify that the methods defined in §192.903 High Consequence Area (1) and/or §192.903 High Consequence Area (2) are applied to each pipeline for the identification of high consequence areas. [§192.905(a)]
[See Details...]A.02 Potential Impact Radius
Verify that the definition and use of potential impact radius for establishment of high consequence areas meets the requirements of §192.903. [§192.905(a)]
[See Details...]A.03 Identified Sites
Verify that the operator's identification of identified sites includes the sources listed in §192.905(b) for those buildings or outside areas meeting the criteria specified by §192.903, and that the source of information selected is documented. [§192.903 Identified Sites, §192.905(b) and §192 Appendix E, I(c)]
[See Details...]A.04 Identification Using Class Locations (Method 1)
If the operator's integrity management program relies on §192.903 High Consequence Area definition (1) for identification of high consequence areas, verify compliance with the following:
[See Details...]A.05 Identification Using Potential Impact Radius (Method 2)
If the operator's integrity management program relies on §192.903 High Consequence Area definition (2) for identification of high consequence areas, verify compliance with the following:
[See Details...]A.06 Identification and Evaluation of Newly Identified HCAs, Program Requirements
Review the operator's integrity management program to verify processes are in place for evaluation of new information that may show that a pipeline segment impacts a high consequence area. [§192.905(c)]
[See Details...]Explanation of Protocol Format
Each protocol element will have top-tier protocols that address the high level requirements. The regulatory requirement upon which the protocol is based is contained in brackets; e.g., [§192.905(a)]
Each top-tier protocol will have detailed "sub-tier" protocols which collectively lead the inspector to draw overall conclusions about compliance with the top-tier protocol. The regulatory requirement, upon which each sub-tier protocol is based, is also contained in brackets.
Notes on protocols:
- The typical sentence structure used in the protocols follows the form of "Verify that [describe the requirement]." The use and meaning of the term "verify" is expanded upon below.
- PHMSA will "verify" an operator’s compliance status with respect to each requirement. In order to perform this verification, PHMSA will inspect the operator’s documented processes and procedures in order to determine if a program has been established that complies with rule requirements. In addition, PHMSA will inspect an operator’s implementation records to determine if the operator is effectively implementing its programs and processes. The purpose of the PHMSA verification/inspection is not to perform a quality check of every integrity related activity. The PHMSA inspection is conducted in the form of an audit. As a result, the PHMSA inspection will typically perform an inspection of selected operator records sufficient in breadth and depth to give the inspection team adequate understanding regarding the degree of an operator's commitment to compliance with applicable requirements and/or the degree to which the operator's program has been effective with respect to achieving compliance. PHMSA may use any number of inspection or audit techniques to identify potential compliance issues. Program documents may be inspected to determine if adequate processes have been developed and documented to the degree necessary for competent professionals to understand and effectively implement the process with results that are consistent and repeatable. For example, one technique that might be used by the inspection team is a "vertical slice" in which a specific covered segment or pipeline system is selected to perform a detailed inspection of every aspect of integrity management, thus following a specific example through the entire process of integrity management. Based on those reviews, OPS will identify potential non-compliances with rule requirements. PHMSA can not and will not certify nor conclude that an operator is in full compliance with rule requirements, even if the inspection does not identify any areas of non-compliance. Operators are wholly responsible for compliance with regulations.
- References to regulatory requirements may include references to specific rule sections/paragraphs and/or to industry standards that are invoked in the rule. As specified in §192.7, any requirement invoked by reference is a requirement of the rule as though it were set out in full in the regulation.
- Protocols are subject to change without notice.
- Protocols are an initial guide for use by OPS inspectors during Integrity Management inspections. Inspectors will develop additional questioning during the course of the inspection to investigate the specifics of an operator's program. Protocols are not to be construed as an exhaustive list of questions that may be presented to operators during an inspection.
- Protocols are made publicly available as a courtesy to operators as they develop their Integrity Management program, as well as other stakeholders.
Protocol: