FAQ 90: Timing for Determining and Performing Preventive and Mitigative Actions
Question: When must operators implement additional preventive and mitigative measures? For example, how long after completing the baseline assessment for a segment can an operator take to conduct a risk analysis and determine whether additional preventive or mitigative actions are needed (including the need for ASVs/RCVs)? If an operator determines that additional actions are warranted, how long does it have to implement them?
Answer: An operator should not wait until after an assessment is conducted to perform its risk analysis and implement appropriate preventive and mitigative measures. Preventive and mitigative actions are a response to the threats faced and the relative risk of the pipeline subject to those threats. It could be valuable for operators to have assessment results in hand to consider when identifying additional preventive and mitigative measures, but the baseline assessment for some segments may not be conducted for several years (e.g., as late as 2012). Operators can, and should, gather enough information before this time to evaluate risk and make the required determinations regarding preventive and mitigative measures. Operators need to document the basis for these determinations, and should have a means of monitoring to determine if the additional measures are effective.
After an operator completes its baseline assessment for a segment, it should revisit its risk analysis, incorporating the results of the integrity assessment and identifying the significant risks that remain. The operator should then analyze those risks to determine if additional actions (or other additional Preventive & Mitigative Measures) should be undertaken. Although the rule establishes no firm time limits by when this risk analysis must be performed, PHMSA believes it is reasonable to expect that this analysis as well as the identification of any additional potential preventive and mitigative actions should be completed within one year after the assessment has been performed. This will allow time for reviewing the assessment results and excavating the worst features, thereby developing confidence in the validity of the assessment and an understanding of the line’s condition.
PHMSA recognizes that the time required to implement preventive and mitigative actions is highly dependent on the proposed risk control activity. Some actions may be simple “quick fix” activities that can readily be implemented in the field. Other actions may involve major capital expenditures and require significant time for budgeting, engineering and design, and implementation. Because of this wide disparity, there is no fixed time requirement for implementing preventive and mitigative actions. PHMSA expects operators to provide a schedule by when additional preventive and mitigative measures will be taken, and to act as quickly as practical after identifying the need for such risk controls. In situations where lengthy periods are required for implementation, operators should determine if there are relatively simple, interim measures that can be taken to reduce risk while major projects are being implemented.