PHMSA Issues Revised Inspection Protocols

PHMSA has published revised inspection protocols on their website. Several of these protocols have revisions that are not apparent unless they are compared to the previous versions. The Operator Qualification Inspection Protocols include additional guidance questions as well as provide a cross-reference to other associated protocol questions. For example, the items in bolded font below are new additions to question 2.01:

2.01 Development of Covered Task List
How did the operator develop its covered task list?

• Verify that the operator applied the four-part test to determine whether 49 CFR Part 192 or 49 CFR Part 195 O&M; activities applicable to the operator are covered tasks. [Enforceable]
• Verify that the operator has identified and documented all applicable covered tasks. [Enforceable] (Associated Protocols: 8.01)

Guidance: The rule requires that the operator identify covered tasks, which are those tasks covered by regulations that meet the four-part test set forth in the Operator Qualification Rule. Investigation of the following characteristics is important to determine whether the requirements of the rule have been met:

1. The method used by the operator to develop its covered task list was thorough, documented, and considered all tasks performed to meet applicable regulatory requirements by employees and contractors.
2. The operator understands the personnel qualification-related activities that pose significant risk to the integrity of pipeline facilities (e.g., excavation and backfilling) and has considered them in the development of its covered task list.
3. The operator identifies how it ensures the addition, revision, or deletion of covered tasks to incorporate changes to operations or regulations.
4. The operator definition of operations and maintenance is consistent with regulatory requirements as they are applied to pipeline facilities.
5. The operator identifies the individuals that are qualified to perform the covered tasks.
6. Review the coverage of each covered task to ensure the task is not too broad of a category, especially for contractors’ use (e.g. Corrosion Control).

The list of recently updated inspection protocols include:

1. PHMSA Form-1 (Standard Inspection Report of a Gas Transmission Pipeline)
2. PHMSA Form-2 (Standard Inspection Report of Gas Distribution Operator)
3. PHMSA Form-3 (Standard Inspection of a Liquid Pipeline Carrier)
4. PHMSA Form-4 (Standard Inspection Report of an LNG Facility)
5. PHMSA Form-5 (Evaluation Report of Gas Pipeline & Compressor Station Construction)
6. PHMSA Form-7 (Evaluation Report of Liquid Pipeline Construction)
7. PHMSA Form-10 (Breakout Tank Inspection Form)
8. PHMSA Form-11 (Pipeline Failure Investigation Report)
9. PHMSA Form-12 (Gas Storage Field Review)
10. PHMSA Form-14 (Operator Qualification Inspection Form)
11. PHMSA Form-15 (Operator Qualification Field Inspection Form)
12. PHMSA Form-18 (Evaluation of LNG Facility Siting, Design, Construction and Equipment)
13. PHMSA Form-19 (Hazardous Liquid IMP Field Verification Inspection)

The inspection protocols can be downloaded at the following website: http://ops.dot.gov/library/forms/forms.htm#7000-1.