PHMSA Gas Transmission (GT) Integrity Management
Time: 05/22/2013 08:32 AM

PHMSA Gas Integrity Management Protocol Results Form

Protocol Areas Protocol B
as Offline Form		 Protocol B
as Offline Document		 Protocol B Outline
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 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 B. Baseline Assessment Plan

  • B.01 Assessment Methods
  • B.02 Prioritized Schedule
  • B.03 Use of Prior Assessments
  • B.04 New HCAs/Newly Installed Pipe
  • B.05 Consideration of Environmental and Safety Risks
  • B.06 Changes

B.01 Assessment Methods

Verify that the operator's Baseline Assessment Plan (BAP) specifies an assessment method(s) for each covered segment that is best suited for identifying anomalies associated with specific threats identified for the segment. [§192.919(b), §192.921(a), §192.921(c), and §192.921(h)]

B.01.a. Verify that the operator followed ASME B31.8S-2004, Section 6.2 and that the assessment method selected for each covered segment addresses all of the threats identified for the segment. More than one assessment tool may be necessary to address all applicable threats to a covered segment. [§192.919(b), §192.921(a), §192.921(c), and §192.921(h)]

B.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)

 

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

 

B.01.b. If internal inspection tools are selected, verify that the operator followed ASME B31.8S-2004, Section 6.2 in selecting the appropriate internal inspection tool for the covered segment. [§192.921(a)(1)]
  1. Verify that the operator has evaluated the general reliability of any in-line assessment method selected by looking at factors including but not limited to: detection sensitivity; anomaly classification; sizing accuracy; location accuracy; requirements for direct examination; history of tool; ability to inspect full length and full circumference of the section; and ability to indicate the presence of multiple cause anomalies. Refer to ASME B31.8S-2004, Section 6.2.5. [§192.921(a)(1)]
B.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)

 

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

 

B.01.c. If a pressure test is specified, verify that the test is required to be conducted in accordance with Part 192, Subpart J requirements. Verify that the operator followed ASME B31.8S-2004, Section 6.3 in selecting the pressure test as the appropriate assessment method. [§192.921(a)(2)]

B.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)

 

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

 

B.01.d. If the operator specifies the use of "other technology," verify that notification to PHMSA is required in accordance with Part 192.949, 180 days before conducting the assessment. Also, verify that notification to a State or local pipeline safety authority is required when either a covered segment is located in a State where PHMSA has an interstate agent agreement, or an intrastate covered segment is regulated by that State. [�192.921(a)(4)]

B.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)

 

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

 

B.01.e. If a covered pipeline segment contains low frequency electric resistance welded pipe (ERW) or lap welded pipe that satisfies the conditions specified in ASME B31.8S-2004, Appendix A4.3 and ASME B31.8S-2004, Appendix A4.4, and any covered or non-covered segment in the pipeline system with such pipe has experienced seam failure, or operating pressure on the covered segment has increased over the maximum operating pressure experienced during the preceding five years verify that the selected assessment method(s) are proven to be capable of assessing seam integrity and detecting seam corrosion anomalies. [§192.917(e)(4)]

B.01.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)

 

B.01.e. Inspection Issues Summary    Leave blank if no issue was identified.

 

B.01.f. If the threat analysis required in §192.917(d) on a plastic transmission pipeline indicates that a covered segment is susceptible to failure from causes other than third-party damage, verify that the operator documents an acceptable justification for the use of an alternative assessment method that will address the identified threats to the covered segment. [§192.921(h)]

B.01.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)

 

B.01.f. Inspection Issues Summary    Leave blank if no issue was identified.

 

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

 

B.01 Inspection Notes

 

B.02 Prioritized Schedule

Verify that the BAP contains a schedule for completing the assessment activities for all covered segments; and that the BAP appropriately considered the applicable risk factors in the prioritization of the schedule. [§192.917(c), §192.919(c) and §192.921]

B.02.a. Verify that the BAP schedule includes all covered segments not already assessed. [§192.921(a)]

B.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)

 

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

 

B.02.b. Verify that the BAP schedule prioritizes the covered segments based on potential threats and applicable risk analysis, and that the risk ranking is appropriate. [§192.917(c) and §192.921(b)]

B.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)

 

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

 

B.02.c. Verify that covered segments meeting the following conditions are prioritized as high-risk segments.
  1. Segments that contain low frequency resistance welded (ERW) pipe or lap welded pipe that satisfy the conditions specified in ASME B31.8S-2004, Appendix A4.3 and ASME B31.8S-2004, Appendix A4.4, and any covered or non-covered segment in the pipeline system with such pipe has experienced seam failure, or operating pressure on the covered segment has increased over the maximum operating pressure experienced during the preceding five years. [§192.917(e)(4)]
  2. Covered segments that have manufacturing or construction defects (including seam defects) where any of the following changes occurred in the covered segment: operating pressure increases above the maximum operating pressure experienced during the preceding five years; MAOP increases; or the stresses leading to cyclic fatigue increase. [§192.917(e)(3)]
B.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)

 

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

 

B.02.d. Verify that the BAP schedule requires 50% of the covered segments, beginning with the highest risk segments, to be assessed by December 17, 2007; and that baseline assessments shall be completed for all covered segments by December 17, 2012. [�192.921(d)]

B.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)

 

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

 

B.02.e. Review the operator's implementation progress to date and verify that: [�192.921]
  1. Assessments scheduled for completion by the date of the inspection were in fact completed.
  2. Assessment methods used for completed assessments were as described in the plan.
  3. The date assessment field activities were completed is recorded so the operator understands the time frame allowable for compliance with the provisions of �192.933.
B.02.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)

 

B.02.e. Inspection Issues Summary    Leave blank if no issue was identified.

 

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

 

B.02 Inspection Notes

 

B.03 Use of Prior Assessments

If prior assessments are used in the BAP, verify that the assessment methods used meet the requirements of §192.921(a) and that remedial actions have been carried out to address conditions listed in §192.933. Prior assessments are those that were completed prior to December 17, 2002. [§192.921(e)]

B.03.a. Verify that threats to these pipeline sections were identified as required under §192.919(a).

B.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)

 

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

 

B.03.b. Verify that the methods used for these prior assessments were appropriate for the threats per ANSI B31.8S-2001 as required under §192.919(b) and §192.919(d).

B.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)

 

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

 

B.03.c. Verify that anomalies satisfying the requirements of §192.933 were repaired.

B.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)

 

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

 

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

 

B.03 Inspection Notes

 

B.04 New HCAs/Newly Installed Pipe

Verify that the operator updates the baseline assessment plan for new HCAs and newly installed pipe. [§192.905(c), §192.921(f), §192.921(g)]

B.04.a. If new HCAs have been identified or new pipe has been installed that is covered by this subpart, verify that applicable segment(s) have been incorporated into the operator's baseline assessment plan within one year from the date the area or pipe is identified and assessments have been appropriately scheduled and/or completed. [§192.905(c)]

B.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)

 

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

 

B.04.b. For new HCAs, verify that the operator completes a baseline assessment for the applicable segment(s) within ten (10) years from the date the area is identified. [§192.921(f)]

B.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)

 

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

 

B.04.c. For newly installed pipe that is covered by this subpart and impacts an HCA, verify that the operator completes a baseline assessment within ten (10) years from the date the pipe is installed. [§192.921(g)]

B.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)

 

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

 

B.04.d. Verify that threats to these pipeline sections were identified as required under §192.919(a). [§192.921(b)]

B.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)

 

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

 

B.04.e. Verify that the assessment methods used were appropriate for the threats per ASME B31.8S-2004 as required under §192.919(b) and 192.919(d).

B.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)

 

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

 

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

 

B.04 Inspection Notes

 

B.05 Consideration of Environmental and Safety Risks

Verify that the operator addresses requirements for conducting the integrity assessments (baseline and reassessment) in a manner that minimizes environmental and safety risks. [§192.919(e) and §192.911(o)]

B.05.a. Verify that precautions were implemented to protect workers, members of the public, and the environment from safety hazards (such as an accidental release of gas) during assessments. [§192.919(e)and §192.911(o)]

B.05.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)

 

B.05.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

B.05 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

B.05 Inspection Notes

 

B.06 Changes

Verify that the operator keeps the BAP up-to-date with respect to newly arising information. Also refer to Protocol K. [§192.911(k) and ASME B31.8S-2004, Section 11]

B.06.a. Verify that the operator's process has requirements to keep the BAP up-to-date with respect to newly arising information, applicable threats, and risks that may require changes to the segment prioritization or assessment method. [§192.911(k) & ASME B31.8S-2004, Section 11]

B.06.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)

 

B.06.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

B.06.b. Verify that required BAP changes have been made and that for all changes, the following are documented: [ASME B31.8S-2004, Section 11(a)]
  1. Reason for change
  2. Authority for approving change
  3. Analysis of implications
  4. Communication of change to affected parties
B.06.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)

 

B.06.b. Inspection Issues Summary    Leave blank if no issue was identified.

 

B.06 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

B.06 Inspection Notes

 

Protocol:
 A  B  C  D  E  F  G  H  I  J  K  L  M  N  O  P 
Protocol Areas Protocol B
as Offline Form		 Protocol B
as Offline Document		 Protocol B Outline
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