More than 75 full-time pipeline inspectors operate out of OPS regional offices in Trenton, NJ; Atlanta, GA; Kansas City, MO; Houston, TX; and Denver, CO. These inspectors conduct a comprehensive inspection and enforcement program to ensure that pipeline operators are complying with all pipeline safety regulations.
It is important to understand, however, that the majority of pipeline inspections in the United States are carried out by state inspectors who work for state agencies.
If a state has a certified pipeline safety program, then it is the state agency that is responsible for conducting inspections of intrastate pipelines. These are lines that lie entirely within a state's borders. Oversight of pipelines that go across state boundaries are known as interstate pipelines (think of interstate highways) and inspections of these are carried out either by OPS or -- in states where OPS and the state have a special agreement in place -- by the state agency.
Several different types of inspections are performed by OPS and state agencies:
Standard Inspections
Standard inspections examine an operator's records and equipment to ensure the operator is complying with applicable regulations. Both gas and hazardous liquid pipeline safety regulations include requirements for operators to periodically perform certain actions, and maintain accurate and thorough records of those actions. Inspectors review records to be certain that critical surveillance and maintenance activities have been performed within prescribed time limits.
Inspectors check a number of both current and historical operating records and parameters as well, including whether the pipeline's maximum pressure is within safe limits. They also examine emergency procedures to determine if operators are prepared to respond promptly and effectively if an abnormal condition or pipeline failure occurs.
In addition to inspecting operator records, procedures and data, inspectors make field visits to physically examine critical pipeline equipment and observe operator personnel implementing required procedures and tests. For example, on standard inspections, inspectors typically observe operator personnel:
- Taking measurements to assure corrosion control equipment is performing effectively;
- Testing pipeline valves to ensure they will operate in the event of an emergency; and
- Checking the settings on instruments and equipment designed to protect against events that could overpressure the pipeline.
During field inspections, inspectors will also observe pipeline ROW markers to ensure the pipeline is adequately marked to make excavators and others aware of its presence.
OPS currently conducts standard inspections on every pipeline every two to three years. Pipelines that are believed to present higher potential for risk are often inspected more frequently. Standard inspections are usually completed within a single week.
Operations and Maintenance Manual Reviews
Pipeline operators are required to have a manual with established procedures dictating how operations and maintenance activities are to be performed. The time required for adequate review of these manuals is more than the time allotted for a standard inspection. For this reason, separate inspections are conducted to review these documents and be sure they meet all requirements. Some important procedures reviewed in these inspections include:
- Procedures for the proper construction, repair, testing, and maintenance of pipelines. This includes methods for repairing or replacing pipe, welding, valve maintenance, and testing and maintenance of overpressure protection devices.
- Procedures to prevent damage to an operator's pipeline due to excavation activities, including right-of-way maintenance, maintaining line markers, participation in One-Call programs, and periodic surveillance of the pipeline right-of-way.
- Procedures that minimize the hazards from a gas pipeline emergency.
Operator Qualification (OQ) Inspections
Operators are required to prepare and follow an operator qualification program. Operator qualification programs must:
- Identify each operator employee or employee of a contractor hired by the operator, who performs certain safety-sensitive operations or maintenance activities on the pipeline system
- Identify the specific tasks that each individual performs
- Ensure that each individual is tested to be certain they have the necessary knowledge, skills and abilities to perform each task, as well as to recognize and react to emergencies that may arise while performing those tasks.
An operator must document the process by which it achieves these objectives. OPS and its state agency partners perform inspections to review OQ program documentation, including the lists of individuals and the tasks they are qualified to perform, records of tests, and other actions required by the plan.
Inspections also include observation of personnel performing selected tasks, as well as discussions with qualified individuals and supervisors to assure that the plan is being implemented effectively. A structured set of inspection protocols has been developed for inspectors to follow in performing OQ inspections.
Integrity Management Inspections
In the context of pipeline operations, the term "integrity" means that a pipeline system maintains its structural integrity and does not leak or rupture. "Integrity management" encompasses the many activities pipeline operators must undertake to ensure that releases do not occur.
Recently-enacted IM regulations place new requirements on operators to provide assurance of safe pipeline operation in locations where a pipeline failure might have significant adverse consequences. These locations are referred to as High Consequence Areas, or HCAs.
Prior to the development of IM regulations and HCA-based decision-making, pipelines in remote and unpopulated areas received just as much scrutiny from operators and regulators as those running through heavily populated areas. Integrity management reflects common sense in protecting the public and in the spending of taxpayer dollars.
The IM rules require:
- Periodic integrity assessment of pipelines that could affect HCAs. Integrity assessments are performed by in-line inspection (also referred to as "smart pigging"), hydrostatic pressure testing, or direct assessment. Through these assessment methods, potentially injurious pipeline defects that have the potential to eventually weaken the pipe, or even cause it to fail, are identified early on and can be repaired, thus improving the pipe's integrity.
- Development and implementation of a set of safety management and analytical processes, collectively referred to as an integrity management program (IMP). The purpose of the program is to assure pipeline operators have systematic, rigorous, and documented processes in place to protect HCAs.
Integrity management inspections are comprehensive, and a team of inspectors is often used to conduct the inspection. For operators with significant pipeline mileage, integrity management inspections generally require two weeks.
For a description of other types of inspections, please follow this link: More...