PHMSA Gas Transmission (GT) Integrity Management
Time: 06/18/2013 06:24 AM

PHMSA Gas Integrity Management Protocol Results Form

Protocol Areas Protocol H
as Offline Form		 Protocol H
as Offline Document		 Protocol H 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 H. Preventive and Mitigative Measures

  • H.01 General Requirements (Identification of Additional Measures)
  • H.02 Third Party Damage
  • H.03 Pipelines Operating Below 30% SMYS
  • H.04 Plastic Transmission Pipeline
  • H.05 Outside Force Damage
  • H.06 Corrosion
  • H.07 Automatic Shut-Off Valves or Remote Control Valves
  • H.08 General Requirements (Implementation of Additional Measures)

H.01 General Requirements (Identification of Additional Measures)

Verify that a process is in place to identify additional measures to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area. [§192.935(a)]

H.01.a. Verify that the process for identifying additional measures is based on identified threats to each pipeline segment and the risk analysis required by §192.917. [Note: Protocol H.08 addresses the implementation decision process for additional preventive and mitigative measures.] [§192.935(a)]

H.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)

 

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

 

H.01.b. Verify that additional measures evaluated by the operator cover a spectrum of alternatives such as, but not limited to, installing Automatic Shut-off Valves or Remote Control Valves, installing computerized monitoring and leak detection systems, replacing pipe segments with pipe of heavier wall thickness, providing additional training to personnel on response procedures, conducting drills with local emergency responders and implementing additional inspection and maintenance programs. [§192.935(a)]

H.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)

 

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

 

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

 

H.01 Inspection Notes

 

H.02 Third Party Damage

Verify that the following preventive and mitigative requirements regarding threats due to third party damage have been addressed: [§192.935(b)(1) and §192.935(e)]

H.02.a. Verify implementation of enhancements to the §192.614-required Damage Prevention Program with respect to covered segments to prevent and minimize the consequences of a release, and that the enhanced measures include, at a minimum: [Note: As noted in Protocol H.03 and Protocol H.04, a subset of these enhancements are required for pipelines operating below 30% SMYS and for plastic transmission pipelines.] [§192.935(b)(1)]
  1. Using qualified personnel (see Protocol L.02 - §192.915(c)) for work an operator is conducting that could adversely affect the integrity of a covered segment, such as marking, locating, and direct supervision of known excavation work. [§192.935(b)(1)(i)]
  2. Collecting, in a central database, location-specific information on excavation damage that occurs in covered and non covered segments in the transmission system and the root cause analysis to support identification of targeted additional preventative and mitigative measures in the high consequence areas. This information must include recognized damage that is not required to be reported as an incident under Part 191. [§192.935(b)(1)(ii)]
  3. Participating in one-call systems in locations where covered segments are present. [§192.935(b)(1)(iii)]
  4. Monitoring of excavations conducted on covered pipeline segments by pipeline personnel. [§192.935(b)(1)(iv)]
    1. When there is physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, verify that the area near the encroachment must be excavated or that an above ground survey using methods defined in NACE RP0502-2002 must be conducted. [§192.935(b)(1)(iv)]
      1. If an above ground survey is conducted, verify that any indication of coating holidays or discontinuities warranting direct examination must be excavated and remediated in accordance with ASME B31.8S-2004, Section 7.5 and §192.933. [§192.935(b)(1)(iv)]
H.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)

 

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

 

H.02.b. If the threat of third party damage is identified by results of the §192.917(b) (Protocol C.02) and ASME B31.8S-2004, Appendix A7 data integration processes, verify that comprehensive additional preventive measures are implemented. [§192.917(e)(1)]

H.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)

 

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

 

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

 

H.02 Inspection Notes

 

H.03 Pipelines Operating Below 30% SMYS

Verify that the following preventive and mitigative requirements for pipelines operating below 30% SMYS have been addressed: [§192.935(d)]

H.03.a. For pipelines operating below 30% SMYS located in a high consequence area:
  1. Verify that the operator's processes for damage prevention program enhancements include requirements for the use of qualified personnel (see Protocol L.02 - §192.915(c)) for work an operator is conducting that could adversely affect the integrity of a covered segment, such as marking, locating, and direct supervision of known excavation work. [§192.935(d) and §192.935(d)(1)] [Note: This requirement is also contained in Protocol H.02.a.i for pipelines operating above 30% SMYS.]
  2. Verify that the operator's processes for damage prevention program enhancements include participating in one-call systems in locations where covered segments are present. [§192.935(d) and §192.935(d)(1)] [Note: This requirement is also contained in Protocol H.02.a.iii for pipelines operating above 30% SMYS.]
  3. Verify that excavations near the pipeline are monitored, or patrols are conducted of the pipeline at bi-monthly intervals as required by §192.705. [§192.935(d) and §192.935(d)(2)]
    1. If indications of unreported construction activity are found, verify that required follow up investigations are conducted to determine if mechanical damage has occurred. [§192.935(d)(2)]
H.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)

 

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

 

H.03.b. For pipelines operating below 30% SMYS located in a class 3 or 4 area but not in a high consequence area:
  1. Verify that the operator's processes for damage prevention program enhancements include requirements for the use of qualified personnel (see Protocol L.02 - §192.915(c)) for work an operator is conducting that could adversely affect the integrity of a covered segment, such as marking, locating, and direct supervision of known excavation work. [§192.935(d), §192.935(d)(1) and §192 Table E.II.1] [Note: This requirement is also contained in Protocol H.02.a.i for pipelines operating above 30% SMYS.]
  2. Verify that the operator's processes for damage prevention program enhancements include participating in one-call systems in locations where covered segments are present. [§192.935(d), §192.935(d)(1) and §192 Table E.II.1] [Note: This requirement is also contained in Protocol H.02.a.iii for pipelines operating above 30% SMYS.]
  3. Verify that excavations near the pipeline are monitored, or patrols are conducted of the pipeline at bi-monthly intervals as required by §192.705. [§192.935(d), §192.935(d)(2) and §192 Table E.II.1]
    1. If indications of unreported construction activity are found, verify that required follow up investigations are conducted to determine if mechanical damage has occurred. [§192.935(d)(2) and §192 Table E.II.1]
  4. Verify that the operator performs semi-annual leak surveys (quarterly for unprotected pipelines or cathodically protected pipe where electrical surveys are impractical). [§192.935(d)(3)and §192 Table E.II.1]
H.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)

 

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

 

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

 

H.03 Inspection Notes

 

H.04 Plastic Transmission Pipeline

For plastic transmission pipelines, verify that applicable third party damage requirements have been applied to covered segments of the pipeline. [§192.935(e)]

H.04.a. Verify that the operator’s processes for damage prevention program enhancements include requirements for the use of qualified personnel (see Protocol L.02 - §192.915(c)) for work an operator is conducting that could adversely affect the integrity of a covered segment, such as marking, locating, and direct supervision of known excavation work. [§192.935(e)] [Note: This requirement is also contained in previous Protocol H.02.a.i for non-plastic pipelines operating above 30% SMYS.]

H.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)

 

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

 

H.04.b. Verify that the operator's processes for damage prevention program enhancements include participating in one-call systems in locations where covered segments are present. [§192.935(e)] [Note: This requirement is also contained in Protocol H.02.a.iii for non-plastic pipelines operating above 30% SMYS.]

H.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)

 

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

 

H.04.c. Verify that the excavations on covered segments are monitored by pipeline personnel. [§192.935(e)] [Note: This requirement is also contained in Protocol H.02.a.iv for non-plastic pipelines operating above 30% SMYS.]
    1. When there is physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, verify that the area near the encroachment must be excavated or that an above ground survey using methods defined in NACE RP0502-2002 must be conducted. [§192.935(e)] [Note: This requirement is also contained in Protocol H.02.a.iv for non-plastic pipelines operating above 30% SMYS.]
      1. If an above ground survey is conducted, verify that any indication of coating holidays or discontinuities warranting direct examination must be excavated and remediated in accordance with ASME B31.8S-2004, Section 7.5 and §192.933. [§192.935(e)] [Note: This requirement is also contained in Protocol H.02.a.iv for non-plastic pipelines operating above 30% SMYS.]
H.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)

 

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

 

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

 

H.04 Inspection Notes

 

H.05 Outside Force Damage

Verify that the operator adequately addresses threats due to outside force (e.g., earth movement, floods, unstable suspension bridge). [§192.935(b)(2)]

H.05.a. If the operator makes a determination that outside force (e.g., earth movement, floods, unstable suspension bridge) is a threat to the integrity of a covered segment (e.g., via Protocol C.01 activities), verify that measures have been taken to minimize the consequences to the covered segment. These measures include, but are not limited to, increasing the frequency of aerial, foot or other methods of patrols, adding external protection, reducing external stress, and relocating the line. [§192.935(b)(2)]

H.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)

 

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

 

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

 

H.05 Inspection Notes

 

H.06 Corrosion

Verify that the operator takes required actions to address corrosion threats. [§192.917(e)(5)]

H.06.a. Verify that the operator makes a determination of whether or not corrosion exists on a covered pipeline segment that could adversely affect the integrity of the line (conditions specified in §192.933). [§192.917(e)(5)]
  1. If such corrosion is identified, then verify that:
    1. The corrosion is evaluated and remediated, as necessary, for all pipeline segments (both covered and noncovered) with similar material coating and environmental characteristics. [§192.917(e)(5)]
    2. A schedule is established for evaluating and remediating, as necessary, the similar segments consistent with the operator's established operating and maintenance procedures under Part 192 for testing and repair. [§192.917(e)(5)]
H.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)

 

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

 

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

 

H.06 Inspection Notes

 

H.07 Automatic Shut-Off Valves or Remote Control Valves

Verify that the operator has a process to decide if automatic shut-off valves or remote control valves represent an efficient means of adding protection to potentially affected high consequence areas. [§192.935(c)]

H.07.a. Verify that an adequate risk analysis-based process is used to determine if an automatic shut-off valve or remote control valve should be added. [§192.935(c)]

  1. Verify that, as a minimum, the following factors were considered: [§192.935(c)]
    1. swiftness of leak detection and pipe shutdown capabilities
    2. the type of gas being transported
    3. operating pressure
    4. the rate of potential release
    5. pipeline profile
    6. the potential for ignition
    7. location of nearest response personnel
H.07.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)

 

H.07.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

H.07 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

H.07 Inspection Notes

 

H.08 General Requirements (Implementation of Additional Measures)

Verify that the operator has identified and implemented (or scheduled) additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area: [§192.935(a)]

H.08.a. Verify that a systematic, documented decision-making process is in place to decide which measures are to be implemented, involving input from relevant parts of the organization such as operations, maintenance, engineering, and corrosion control. [§192.935(a)]

H.08.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)

 

H.08.a. Inspection Issues Summary    Leave blank if no issue was identified.

 

H.08.b. Verify that the decision-making process considers both the likelihood and consequences of pipeline failures. [§192.935(a)]

H.08.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)

 

H.08.b. Inspection Issues Summary    Leave blank if no issue was identified.

 

H.08.c. Verify that additional measures are identified and documented and have actually been implemented, or scheduled for implementation. [§192.935(a)]

H.08.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)

 

H.08.c. Inspection Issues Summary    Leave blank if no issue was identified.

 

H.08 Documents Reviewed    (Tab from bottom-right cell to add additional rows.)
Document Number Rev Date Document Title

 

H.08 Inspection Notes

 

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