Protocol:
A B C D E F G H I J K L M N O P 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)]
[See Details...]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]
[See Details...]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)]
[See Details...]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)]
[See Details...]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)]
[See Details...]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]
[See Details...]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:
A B C D E F G H I J K L M N O P