PHMSA Gas Transmission (GT) Integrity Management
Time: 11/22/2014 05:31 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 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
  • I.02 Performance Measures Records Verification
  • I.03 Exceptional Performance Measurements

I.01 General Performance Measures

Inspect the operator's program to verify that provisions exist for measuring integrity management program effectiveness and that the operator is tracking 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 the process for measuring IM program effectiveness includes the elements necessary to conduct a meaningful evaluation.

An adequate process for measuring IM program effectiveness should have the following characteristics:
  • Includes the use of periodic self-assessments, internal and/or external integrity management program audits, management reviews, or other self-critical evaluations to measure program effectiveness.
  • Includes a clear description of the scope, objectives, and frequency of these program evaluation methods.
  • Includes bench-marking performance metrics using data from inside or outside the company.
  • Clearly defines the use of performance metrics in evaluating program performance.
  • Provides for feedback to corrective action programs, preventive and mitigative measures decisions, and the threat and risk analysis processes? Does this feedback include communicating lessons learned and noteworthy practices to the appropriate individuals/organizational units.
  • Assures management awareness and commitment, including the resources required to address integrity program improvements identified through performance measurement.
  • Includes provisions for the review and follow-up of program effectiveness evaluation results, findings, and recommendations, etc., with appropriate company managers.
  • Includes provisions for the assignment of responsibility, by organization, group, or title, for implementation of required actions.
  • Requires evaluation of the effectiveness of programs to address specific threats in accordance with ASME B31.8S-2004 Appendix A.
I.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)

 

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

 

I.01.b. Verify the process to evaluate IM program effectiveness includes an adequate set of performance metrics to provide meaningful insight into IM program performance.

A process for identifying an adequate set of performance measures should have the following characteristics:
  • Includes a description of the performance metrics to be used and the frequency for data collection.
  • Defines metrics that:
    • Provide an overall measure of program effectiveness such as number of leaks or ruptures, etc.,
    • Reflect the accomplishment of the program's objectives such as number of miles of pipeline assessed; number of anomalies found requiring repair or mitigation; number of right-of-way encroachments, and
    • Provide threat-specific insight in accordance with ASME B31.8S – 2004, Appendix A. Examples include: the number of leaks caused by each threat (e.g., internal/external corrosion, third party damage, etc.); number of repair actions taken for each threat, etc.
  • Includes performance metrics developed in accordance with ASME B 31.8S-2004 Section 9 including:
    • Process/Activity Metrics that monitor the surveillance and preventive activities that are in place to control risk. These metrics indicate how well an operator is implementing the elements of its integrity management program.
    • Operational Measures that monitor operational and maintenance trends to indicate if the program is effective or ineffective, or the desired outcome is being achieved or not, despite the risk control activities in place.
    • Direct Integrity Metrics that reflect whether the program is effective in achieving the objective of improving integrity. These are typically lagging indicators that measure the number of leaks, ruptures, injuries, fatalities, etc.
  • Includes trending of metrics over time and an analysis of these trends? The process for trending should include:
    • A method to establish the magnitude of trends that represent normal fluctuations versus significant deviations (e.g., significant enough to warrant corrective action).
    • The trending of equipment or material failures (e.g., valve gaskets or pump seals) as a means to evaluate pipeline deterioration (an indicator of the end of useful life of materials and components).
    • The trending of leading indicators such as inadvertent over-pressurization, right-of-way encroachments without one-call notification, SCADA outages, operation of overpressure or other safety devices, or other abnormal operating conditions such as those listed in 192.605(c). (Leading indicators measure the effectiveness of proactive activities to control risk. These indicators can uncover weaknesses before they develop into full-fledged problems.)
  • Provides for the periodic review and revision (if needed) of performance metrics to assure they are providing useful information about the effectiveness of IM Program activities.
  • Includes procedures to ensure the completeness and accuracy of performance measure data – both for metrics reported to PHMSA and the metrics used internally.
  • Defines performance goals, including segment-specific issues related to the operator's unique operating environment such as a decrease in the number, and depth, of corrosion related anomalies, a decrease in the threat of mechanical damage due to a decrease in one-calls, a decrease in the number of crack anomalies, etc.
  • Provides for the periodic review of performance goals and their revision (if needed) based on the results of program evaluations.
  • Includes comparing leak, failure, and incident metrics to risk model results, and uses these comparisons to modify the risk model if necessary.
I.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)

 

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

 

I.01.c. Verify that performance is measured annually (completed through 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.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)

 

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

 

I.01.d. Verify that performance is measured 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.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)

 

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

 

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

 

I.01 Inspection Notes

 

I.02 Performance Measures Records Verification

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

I.02.a The methods to measure program effectiveness provide effective evaluation of IM program performance and result in program improvements where necessary?

The records to demonstrate IM program effectiveness should have the following characteristics:
  • The records show that periodic self-assessments, internal and/or external audits, management reviews, or other self-critical program evaluations have been performed at the established frequency.
  • The records indicate that the process has been implemented consistent with its scope and objectives, and at the established frequency.
  • The records show that these program evaluations provided a comprehensive and in-depth examination of performance, and effectively used the established performance metrics in this process.
  • The records show bench-marking performance using data from inside or outside the company.
  • The records show evidence of feedback to corrective action programs, preventive and mitigative measures decisions, and the threat and risk analysis processes.
  • The records show that lessons learned and best practices have been communicated to the appropriate individuals and organizational units.
  • The records show evidence of management awareness and commitment, including providing resources to address improvements identified by the program evaluation.
  • The records include the review and follow-up of program evaluation results, findings, and recommendations, etc., by appropriate company managers.
  • The records include the assignment of responsibility, by organization, group, or title, for implementing required actions.
  • The records show that deficiencies identified in program evaluations and recommended improvements have been implemented in a timely manner.
I.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)

 

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

 

I.02.b That performance metrics are providing meaningful insight into integrity management program effectiveness.

Records to demonstrate that performance metrics are providing meaningful insights into IM program effectiveness should have the following characteristics:
  • The records show the performance measure data is being collected and at the frequency established in the program evaluation process.
  • The records show that overall metrics have been defined and data collected for:
    • Overall measures of program effectiveness such as number of leaks, or ruptures, etc.,
    • Metrics that reflect the accomplishment of the program's objectives, and
    • Threat specific metrics as established in ASME B31.8S-2004, Appendix A.
  • The records show that the performance metrics developed in accordance with ASME B 31.8S-2004 Section 9 were implemented. Specifically,
    • Process/Activity Metrics that monitor the surveillance and preventive activities that are in place to control risk. These metrics indicate how well an operator is implementing the elements of its integrity management program.
    • Operational Measures that monitor operational and maintenance trends to indicate if the program is effective or ineffective, or the desired outcome is being achieved or not, despite the risk control activities in place.
    • Direct Integrity Metrics that reflect whether the program is effective in achieving the objective of improving integrity. These are typically lagging indicators that measure the number of leaks, ruptures, injuries, fatalities, etc.
  • The records show the trending of metrics over time and an analysis of these trends. Specifically,
    • Do records show the trending analysis includes method(s) to establish the magnitude of trends that represent normal fluctuations versus significant deviations (e.g., significant enough to warrant corrective action).
    • Do records show trending of equipment or material failures as a means to evaluate pipeline equipment deterioration.
    • Do records show trending of leading indicators such as inadvertent over-pressurization, ROW encroachments without one-call notification, SCADA outages, operation of overpressure or other safety devices, or other abnormal operating conditions such as those listed in 192.605(c). (Leading indicators measure the effectiveness of proactive activities to control risk. These indicators can uncover weaknesses before they develop into full-fledged problems.)
  • The records show that the performance metrics have been reviewed and updated if needed to assure they are providing useful information about the effectiveness of IM Program activities.
  • The records show that the operator has implemented its program to assure the completeness and accuracy of the data used to measure performance.
  • The records show that the IM performance measures reported to PHMSA are complete and accurate.
  • The records show any data quality concerns that might exist.
  • The records show that the operator has established specific performance goals, including segment specific issues related to the operator's unique operating environment such as the number, and depth, of corrosion related anomalies, the threat of mechanical damage due to one calls, the number of crack anomalies, etc.
  • The records show that the performance goals have been reviewed and revised based on the results of program evaluations.
  • The records show the leak, failure, and incident metrics have been compared to the risk model, and that changes to the risk model have been made when the data indicates such changes are necessary.
I.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)

 

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

 

I.02.c The four overall performance measures of ASME B31.8S-2004, Section 9.4 have been submitted to PHMSA annually in accordance with §192.951.

I.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)

 

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

 

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

 

I.02 Inspection Notes

 

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.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)

 

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

 

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

I.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)

 

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

 

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

 

I.03 Inspection Notes

 

Protocol:
 A  B  C  D  E  F  G  H  I  J  K  L  M  N  O  P 
PHMSA Home | Pipeline Safety Website | Feedback | Privacy Policy | FOIA