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.

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 Area I. Performance Measures

I.01 General Performance Measures

Inspect the operator's program to verify that, as a minimum, provisions exist for measuring integrity management program effectiveness in accordance with the four elements of ASME B31.8S-2004, Section 9.4 and each identified threat in ASME B31.8S-2004, Appendix A. [§192.945(a) and ASME B31.8S-2004, Section 12(b)(5)]

I.01.a. Verify that performance is measured semi-annually (completed through June 30th and December 31st of each year) for each of the following: [ASME B31.8S-2004, Section 9.4]

Number of miles of pipeline inspected versus program requirements
Number of immediate repairs completed as a result of the integrity management inspection program
Number of scheduled repairs completed as a result of the integrity management program
Number of leaks, failures and incidents (classified by cause).

I.01.b. Verify that performance is measured semi-annually in accordance with the threat-specific metrics of ASME B31.8S-2004, Appendix A (See ASME B31.8S-2004, Table 9 for a summary listing).

I.02 Performance Measures Records Verification

Inspect operator records to verify: [§192.945(a)]

I.02.a The four overall performance measures of ASME B31.8S-2004, Section 9.4 have been submitted to PHMSA on a semi-annual basis in accordance with ďż˝192.951. Note: Initial report by August 31, 2004, semi-annual reports by February 28th (or 29th) and August 31st of each year thereafter. [ďż˝192.945(a)]

I.03 Exceptional Performance Measurements

For operators that choose to demonstrate exceptional performance in order to deviate from certain requirements of the rule, verify the following.

I.03.a. Additional performance measures beyond those required in §192.945 (see Protocol I.01) are part of the operator's performance plan. [§192.913(b)(vii)]

I.03.b. All performance measures (all measures required by ďż˝192.945 and the additional performance measures) are submitted to PHMSA on a semi-annual frequency in accordance with ďż˝192.951. [ďż˝192.913(b)(vii)]