PHMSA Gas Transmission (GT) Integrity Management
Time: 08/28/2014 05:22 AM

Protocol Item E.04

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]

  1. 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)]

  1. 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)]

  1. 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)]

  1. 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)]

  1. 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)]
  1. 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)]
  1. Verify that remediation activities were completed in accordance with scheduled timeframes. [192.933(c) and 192.933(d)]

  1. 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)]

  1. 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)]

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