PHMSA Gas Integrity Management Protocols
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.
- L.01 Program Requirements for the Quality Assurance Process
- L.02 Personnel Qualification and Training Requirements
- L.03 Invoking Non-Mandatory Statements in Standards
L.01 Program Requirements for the Quality Assurance Process
Verify that a quality assurance process exists that meets the requirements of ASME B31.8S-2004, Section 12. [§192.911(l)]
L.01.a. Verify that responsibilities and authorities for the integrity management program have been formally defined. [ASME B31.8S-2004, Section 12.2(b)(2)]
L.01.b. Verify that reviews of the integrity management program and the quality assurance program have been specified to be performed on regular intervals, making recommendations for improvement. [ASME B31.8S-2004, Section 12.2(b)(3)]
L.01.c. Verify that corrective actions to improve the integrity management program and the quality assurance process have been documented and are monitored for effectiveness. [ASME B31.8S-2004, Section 12.2(b)(7)]
L.01.d. Verify that when an operator chooses to use outside resources to conduct any process that affects the quality of the integrity management program, the operator ensures the quality of such processes and documents them within the quality program. [ASME B31.8S-2004, Section 12.2(c)]
L.02 Personnel Qualification and Training Requirements
Verify that personnel involved in the integrity management program are qualified for their assigned responsibilities. [§192.911(l), §192.915 and ASME B31.8S-2004, Section 12(b)(4)]
L.02.a. Verify that the Integrity Management Program requires supervisory personnel to have the appropriate training or experience for their assigned responsibilities. [§192.915(a)]
L.02.b. Verify the qualification of personnel that carry out assessments and who evaluate assessment results. [§192.915(b)]
L.02.c. Verify the qualification of personnel who participate in implementing preventive and mitigative measures including: [§192.915(c)]
- Personnel who mark and locate buried structures.
- Personnel who directly supervise excavation work.
- Other personnel who participate in implementing preventive and mitigative measures as appropriate. [ASME B31.8S-2004, Section 12.2(b)(4)]
L.02.d. Verify that the personnel who execute the activities within the integrity management program are competent and properly trained in accordance with the quality control plan. [ASME B31.8S-2004, Section 11(a)(8) and ASME B31.8S-2004, Section 12.2(b)(4)]
L.03 Invoking Non-Mandatory Statements in Standards
Verify that non-mandatory requirements (e.g., "should" statements) from industry standards or other documents invoked by Subpart O (e.g., ASME B31.8S-2004 and NACE RP0502-2002) are addressed by one of the following approaches: [§192.7(a)]
L.03.a. Incorporated into the operator's plan and implemented as recommended in the standard; or
L.03.b. An equivalent alternative method for accomplishing the same objective is justified and implemented; or
L.03.c. A documented justification is included in the plan that demonstrates the technical basis for not implementing recommendations from standards or other documents invoked by Subpart O.