PHMSA Gas Transmission (GT) Integrity Management
Time: 10/24/2014 04:05 PM

PHMSA Gas Integrity Management Protocol Results Form

Protocol:
 A  B  C  D  E  F  G  H  I  J  K  L  M  N  O  P 

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 operators compliance status with respect to each requirement. In order to perform this verification, PHMSA will inspect the operators 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 operators 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 E. Remediation

  • E.01 Program Requirements for Discovery, Evaluation and Remediation Scheduling
  • E.02 Program Requirements for Identifying Anomalies
  • E.03 Operator Response when Timelines for Evaluation and Remediation Cannot be Met
  • E.04 Record Review for Discovery, Repair and Remediation Activities

E.01 Program Requirements for Discovery, Evaluation and Remediation Scheduling

Verify that provisions exist to discover and evaluate all anomalous conditions resulting from integrity assessment and remediate those which could reduce a pipeline's integrity. [192.933(a)]

E.01.a. Verify a definition of discovery is provided. [192.933(b)]

E.01.a. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.01.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.01.b. Verify a requirement exists to document the actual date of discovery. [192.933(b)]

E.01.b. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.01.b. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.01.c. Verify a requirement exists to develop a schedule that prioritizes evaluation and remediation of anomalous conditions. [192.933(c)]

E.01.c. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.01.c. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.01.d. If the operator desires to deviate from the timelines for remediation as provided in 192.933 by demonstrating exceptional performance, verify that the requirements of 192.913(b) have been met and the safety of the covered segment is not jeopardized. [192.913(c)(2)](See Protocol F.05)

E.01.d. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.01.d. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.01 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

E.01 Inspection Notes

 

E.02 Program Requirements for Identifying Anomalies

Inspect the operator's program to verify that provisions exist for the classification and remediation of anomalies that meet the criteria for: (1) Immediate repair conditions; (2) One-year conditions; (3) Monitored conditions; or (4) Other conditions as specified in ASME B31.8S-2004, Section 7 . [�192.933(c) and �192.933(d)]

E.02.a. Verify the program requires a temporary pressure reduction or the pipeline to be shut down upon discovery of all immediate repair conditions. [�192.933(d)(1)]

E.02.a. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.02.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.02.b. Verify provisions exist to classify and categorize anomalies meeting the following criteria:
  1. Immediate Repair Conditions (Conditions requiring immediate remediation actions)
    1. Calculated remaining strength indicates a failure pressure that is less than or equal to 1.1 times MAOP; [�192.933(d)(1)]
    2. A dent having any indication of metal loss, cracking, or a stress riser; [�192.933(d)(1)]
    3. An indication or anomaly that is judged by the person designated by the operator to evaluate assessment results as requiring immediate action. [�192.933(d)(1)]
    4. Metal-loss indications affecting a detected longitudinal seam if that seam was formed by direct current or low-frequency electric resistance welding or by electric flash welding; [ASME B31.8S-2004, Section 7.2.1]
    5. All indications of stress corrosion cracks; [ASME B31.8S-2004, Section 7.2.2]; or
    6. Any indications that might be expected to cause immediate or near-term leaks or ruptures based on their known or perceived effects on the strength of the pipeline. [ASME B31.8S-2004, Section 7.2.3]
  2. One-Year Conditions (Conditions requiring remediation within one year of discovery).
    1. A smooth dent located between the 8 and 4 o'clock positions (upper 2/3 of the pipe) with a depth greater than 6% of the pipeline diameter; [�192.933(d)(2)] or,
    2. A dent with a depth greater than 2% of the pipeline's diameter, that affects pipe curvature at a girth weld or at a longitudinal seam weld. [�192.933(d)(2)]
  3. Monitored Conditions (Conditions which must be monitored until the next assessment).
    1. A dent with a depth greater than 6% of the pipeline diameter located between the 4 and 8 o'clock position (lower 1/3) of the pipe; [�192.933(d)(3)]
    2. A dent located between the 8 and 4 o'clock position (upper 2/3) of the pipe with a depth greater than 6% of the pipeline diameter, and engineering analysis to demonstrate critical strain levels are not exceeded; [�192.933(d)(3)]or,
    3. A dent with a depth greater than 2% of the pipeline diameter, that affects pipe curvature at a girth weld or a longitudinal seam weld, and engineering analysis of the dent and girth or seam weld to demonstrate critical strain levels are not exceeded. [�192.933(d)(3)]
E.02.b. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.02.b. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.02.c. Verify provisions exist to record and monitor anomalies that are classified as "monitored conditions" during subsequent risk or integrity assessments for any change in their status that would require remediation. [�192.933(d)(3)]

E.02.c. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.02.c. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.02.d. Verify that program requirements exist to meet the provisions of ASME B31.8S-2004, Section 7, Figure 4 for scheduling and remediating any other threat conditions that do not meet the classification criteria of Protocol E.02.b, above. [�192.933(c)]

E.02.d. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.02.d. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.02 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

E.02 Inspection Notes

 

E.03 Operator Response when Timelines for Evaluation and Remediation Cannot be Met

Verify that provisions exist to respond appropriately when the operator is unable to meet time limits for evaluation and remediation. [192.933(a)].

E.03.a. Verify a requirement exists to take a temporary operating pressure reduction or other action that ensures safety of the covered segment in the event the operator is unable to respond within the timeframes required by �192.933. [�192.933(a)]
  1. Verify a requirement exists to determine the appropriate pressure reduction using ASME B31G, or "RSTRENG", or reduce pressure to a level not exceeding 80% of the level at the time the condition was discovered. [�192.933(a)]
  2. Verify a requirement exists that when a pressure reduction is to exceed 365 days, a documented technical justification is developed that explains the reason for remediation delay and demonstrates continuation of the reduction will not jeopardize pipeline integrity. [§192.933(a)]
E.03.a. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.03.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.03.b. Verify a requirement exists to document the justification, when an evaluation and a remediation activity cannot be completed within established timeframe requirements, that includes the reasons why the schedule cannot be met and the basis for why the changed schedule will not jeopardize public safety. [[§192.933(a) and §192.933(c)]

E.03.b. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.03.b. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.03.c. Verify a requirement exists to notify PHMSA in accordance with §192.949 and the State or local pipeline safety authority, if applicable, when:
  1. the operator cannot meet the evaluation and remediation schedule and cannot provide a temporary reduction in operating pressure or other action. [ [§192.933(a)(1) and §192.933(c)], and
  2. a pressure reduction exceeds 365 days. [§192.933(a)(2)]

The notification is to include the documented justification under protocols E.03.a and E.03.b.

E.03.c. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.03.c. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.03 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

E.03 Inspection Notes

 

E.04 Record Review for Discovery, Repair and Remediation Activities

Inspect operator repair and remediation records to verify that remediation activities have been conducted in accordance with program requirements. [192.933]

E.04.a. Verify a prioritized schedule exists for evaluation and remediation of anomalies identified during assessment or reassessment activities. The prioritized schedule must document which of the criteria specified in 192.933(d) and/or ASME B31.8S-2004 were used as the basis for the schedule. [192.933(c) and 192.933(d)]

E.04.a. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.b. Verify anomaly discovery was documented within 180 days of completion of the assessment or reassessment, or else that compliance with the 180-day period was impracticable. [192.933(b)]

E.04.b. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.b. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.c. Verify any remediation activities taken are sufficient to ensure that the anomaly is unlikely to threaten the integrity of the pipeline before the next scheduled reassessment. [192.933(a)]

E.04.c. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.c. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.d. Verify, for any immediate repair anomalies, a temporary pressure reduction is taken by the operator on the pipeline and the reduced pressure is determined in accordance with ASME B31G, or "RSTRENG", or that the reduced pressure does not exceed 80% of the level at the time the condition was discovered. [192.933(a)]

E.04.d. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.d. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.e. Verify immediate repair conditions have been evaluated and remediated on a
schedule established in accordance with the provisions of ASME B31.8S-2004, Section 7. [192.933(d)(1)]
E.04.e. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.e. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.f. Verify any pressure reduction taken has not exceeded 365 days from the date of discovery unless:
  1. a technical justification has been developed that explains the reason for remediation delay andto demonstrates that continuation of the pressure reduction will not jeopardize the integrity of the pipeline, and
  2. PHMSA and the State pipeline safety authority, if applicable, have been notified in accordance with §192.949. [§192.933(a)]
E.04.f. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.f. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.g. Verify that remediation activities were completed in accordance with scheduled timeframes. [192.933(c) and 192.933(d)]

E.04.g. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.g. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.h. Verify that anomalies meeting any of the criteria of 192.933(d)(3) as "monitored conditions" are evaluated during subsequent risk and integrity assessments to identify any change that may require remediation and that any required remediation is scheduled and implemented in accordance with the applicable requirements of 192.933 and ASME B31.8S-2004. [192.933(d)]

E.04.h. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.h. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04.i. Verify any remediation activities that have not been completed in accordance with §192.933 timeframes, and the operator has not provided safety through a temporary pressure reduction:
  1. have technical justifications that include the reasons why the schedule cannot be met and the basis for why the changed schedule will not jeopardize public safety, and
  2. have been reported to OPS PHMSA and appropriate State or local authorities in accordance with the requirements of §192.933(c) of the rule. [§192.933(c)]
E.04.i. Inspection Results    Type an "X" in the applicable box below. Select only one.
No Issues Identified
Potential Issues Identified (explain in summary)
Not Applicable (explain in summary)

 

E.04.i. Inspection Issues Summary    Leave blank if no issue was identified.

 

E.04 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

E.04 Inspection Notes

 

Protocol:
 A  B  C  D  E  F  G  H  I  J  K  L  M  N  O  P 
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