Frequently-Asked Question FAQ #180

FAQ-180: Enhancing already-enhanced P&M

Question: How will OPS evaluate required "enhancements" for operators that are already operating at high level with respect to damage prevention measures?

Answer: Section 192.935(b) requires that operators take specific actions to address the threat of third-party damage. In addition, section 192.935(a) requires that "An operator must take 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." (emphasis added). Section 192.935(a) further requires that "An operator must conduct...a risk analysis of its pipeline to identify additional measures...".

The rule does not require that operators implement additional actions beyond those they presently implement, only that they implement actions beyond those already required. Operators who are already implementing protective measures that go beyond the regulations may not need to do more unless their risk analysis indicates otherwise. OPS inspections will include an evaluation of the operator’s risk analysis and will consider whether additional protective measures that have been implemented are consistent with its conclusions.