Pipeline Safety III: Integrated Pipeline Inspections

Tue, 2012-01-24


In Part I of our series on Pipeline Safety, we discussed the safety responsibilities of pipeline operators, to help properly manage System Integrity, Maintenance, Leak Detection, Training, and Emergency Preparedness.

In Part II, we outlined the National Consensus Standards that the Pipeline and Hazardous M
aterials Safety Administration (PHMSA) recognizes. 


This article explains the three different types
of integrated inspections that are performed by the Office of Pipeline Safety (OPS) and their State partners.  It also includes a detailed look at the differences between standard inspection requirements for various pipeline system types.

Use these links to jump to the information you are interested in:

Establishing An Integrated Inspection Process
Standard Inspections
Operator Qualification (OQ) Inspections
Integrity Management (IM) Inspections


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NOTE: The information presented in this document is intended for general discussion only and should not be used for compliance purposes.

Establishing An Integrated Inspection Process

 

Pipeline safety regulations were originally established in the early 1970s and were based primarily on industry consensus standards in effect at the time.  While these regulations have been updated throughout the years, several significant new regulatory programs were created early in the 21st century.

In 2008, OPS began pilot testing an integrated inspection process.  By using data and information about the operator and the pipeline system, an inspector custom builds a list of regulatory requirements that are evaluated during the inspection of specific pipeline systems.  This data-driven process allows OPS to focus inspection resources on the regulatory provisions representing the greatest risk.

OPS maintains the ability to conduct the program-based inspections listed below, but has been conducting an increasing number of integrated inspections since 2008. State partners may choose to conduct integrated inspections, or continue with the program-based inspections.

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Standard Inspections

 

Standard inspections review operator compliance with the pipeline safety regulations originally put in place in the early 1970s.  Both gas and hazardous liquid pipeline safety regulations include minimum requirements for an operator to safely operate and maintain its system.  

Inspections review operator procedures and records of maintenance as well as observations of operator employees implementing the procedures.  Inspectors also check operating records to ensure the pipeline system is operated at or below the maximum value allowed by regulations.  They also examine emergency procedures to determine if operators are prepared to respond promptly and effectively if an abnormal condition or pipeline failure occurs. 

Different standard inspections are required for various pipeline system types.  Standard inspections are performed for operators, facilities, and even construction projects to ensure that they are in compliance with the applicable Code of Federal Regulations (also known as CFR) in all the following areas:

Gas Transmission Operators– Gas transmission operators are inspected to ensure that they comply with all applicable sections of 49 CFR Part 192, Transportation of Natural/Other Gas by Pipeline.  

This inspection includes a review to ensure that all of the following are in compliance with applicable regulations:

  • Operation and maintenance procedures
  • Abnormal and emergency operating procedures
  • Damage prevention and public education procedures
  • Pipeline repair and operations

Gas Distribution Operators– Gas distribution operators are inspected to ensure they comply with all applicable sections of 49 CFR Part 192 Transportation of Natural/Other Gas by Pipeline.  

This inspection includes a review to ensure that all of the following are in compliance with applicable regulations:

  • Operation and maintenance procedures
  • Abnormal and emergency operating procedures
  • Damage prevention and public education procedures
  • Pipeline installation, connection, repair and operations

Liquid Pipeline Operators– Hazardous liquid operators are inspected to ensure they comply with all applicable sections of 49 CFR Part 195, Transportation of Hazardous Liquids by Pipeline.  

This inspection includes a review to ensure that the following are in compliance with applicable regulations:

  • Operation and maintenance procedures
  • Abnormal and emergency operating procedures
  • Damage prevention and public education procedures
  • Pipeline repair and operations

Liquefied Natural Gas Facilities– LNG facilities are inspected to ensure they comply with 49 CFR Part 193, Liquefied Natural Gas Facilities.  

This inspection includes a review to ensure that all of the following comply with the applicable sections of this regulation:

  • Operation and maintenance procedures
  • Emergency operating procedures
  • Corrosion control
  • Repair and operations

Breakout Tanks– breakout tanks are inspected to ensure they are in compliance with the applicable sections of 49 CFR Part 195, Transportation of Hazardous Liquids by Pipeline.  

This inspection also includes a review of:

  • The Facility Response Plan
  • Operation and maintenance procedures
  • Corrosion control
  • Over-pressure and over-fill protection
  • Impoundment (containment in the event of a spill or rupture)
  • The operator’s in-service inspection program
  • Safety procedures

Gas Storage Fields– Gas storage fields are inspected to ensure they are in compliance with applicable sections of 49 CFR Part 192, Transportation of Natural/Other Gas by Pipeline.  

This inspection also includes a review of:

  • Over-pressure protection
  • Corrosion control
  • Repairs and maintenance
  • Environmental sampling
  • Internal erosion control
  • Gas and fire detection

Construction– Inspections are performed on Liquefied Natural Gas Facility, Gas Transmission and Compressor, and Hazardous Liquid Pipeline Construction Projects to ensure they are in compliance with applicable sections of 49 CFR Parts 192, 193, and 195.

This inspections include a review of:

  • Material and component design specifications
  • Welding procedures and welder qualifications
  • Non-destructive testing results
  • Corrosion protection
  • Installation
  • Post-construction testing

LNG facility construction inspections include a review of the siting analysis, wind loads, and compliance with NFPA requirements.

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Source:

http://primis.phmsa.dot.gov/comm/InspectionDetails.htm?nocache=9387

Operator Qualification (OQ) Inspections

 

In 2001, pipeline safety regulations were revised to require pipeline operators to document the training of employees.  Operators are required to prepare a written operator qualification program that identifies employee positions that perform safety-sensitive operation or maintenance tasks.  Employees in these positions must be trained and tested to ensure they have the necessary knowledge, skills and abilities to perform each task, as well as the ability to recognize and react to emergencies that may arise while performing those tasks.

OPS and State Inspections verify that operators have created an acceptable OQ program and identified all safety-sensitive employee positions. Inspectors also review records to verify that employees in these positions have been trained and tested.  Operator employees performing operations and maintenance tasks are observed to ensure the tasks are completed in accordance with the operator’s program.

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Integrity Management (IM) Inspections

 

"Integrity" in pipeline operations is best defined as a pipeline system that maintains its structural integrity and does not leak or rupture.  "Integrity Management" encompasses the many activities pipeline operators must undertake to ensure that leaks or ruptures do not occur.

Pipeline safety IM regulations were implemented for different pipeline system types early in the 21st century.  The first regulations were for hazardous liquids in 2001, followed by gas transmission in 2004, then gas distribution in 2009.  Since each of these system types have unique operating characteristics, the IM regulations are tailored to the system type.  A separate briefing on integrity management is available through the PHMSA website.  

Select one of these links for more detailed information:

Inspections of IM programs generally verify that an operator uses all available information about its pipeline system to assess risks and take appropriate action to mitigate those risks.  Inspections include reviewing the written IM program and associated records.

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Source:
http://primis.phmsa.dot.gov/comm/Inspection.htm