The Pipeline Safety Improvement Act of 2002 requires the Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration/ Office of Pipeline Safety (PHMSA/OPS) to issue regulations prescribing standards to direct natural gas system operators to establish and implement an integrity management program and conduct a risk analysis of its transmission lines which are typically larger diameter (6”-36”) steel pipe operating at pressures from 400 psig to over 1000 psig.
The statute sets forth minimum requirements for integrity management programs for gas transmission pipelines located in High Consequence Areas (HCAs) or areas in close proximity to a DOT pipeline that contain high population density and/or “identified sites” (facilities housing people with limited or impaired mobility such as hospital, school, prison, recreation areas, etc.). These requirements are incorporated into 49 Code of Federal Regulations (CFR) Part 192, Subpart “O”.
This regulation mandates that we develop and maintain an Integrity Management Plan (IMP) that addresses regulatory requirements. The IMP is a systematic and comprehensive program designed to obtain information on existing transmission pipelines to more effectively allocate resources in the prevention, detection and mitigation activities needed to improve pipeline safety.
Statutory requirements for an integrity program include the following:
- Conducting baseline inspections and reassessment of each covered transmission pipeline segment at specified intervals
- Conducting integrated data analysis on a continuous basis
- Taking actions to address integrity concerns
- Addressing issues raised by PHMSA/OPS
- Conducting inspections in an environmentally appropriate manner
- Providing notification of changes to a program
- Permitting state or OPS agencies access to the risk analysis and integrity management program
Elements of Our IMP
- HCA Identification
- Evaluation/ Reassessment
- Threat Identification
- Management of Change
- Risk Assessment and Prioritization
- Quality Assurance
- Development of Baseline Assessment Plan
- Record Keeping
- Conducting Assessments
- Performance Planning/Reporting
- Remediation of Anomalies
- Communications Plan
- Preventive and Mitigative Measures
- Regulatory/Public Interaction
The program requires completion of the baseline assessments for the top 50% risk-ranked transmission lines by December 17, 2007 and the remainder by December 17, 2012.