On November 15, 2002, Congress passed the Pipeline Safety Improvement Act of 2002. This law requires the Department of Transportation’s (DOT) branch Pipeline and Hazardous Materials Safety Administration/ Office of Pipeline Safety (PHMSA/OPS) to issue regulations prescribing standards to direct a natural gas system operator to conduct a risk analysis and adopt and implement an integrity management program. The statute sets forth minimum requirements for integrity management programs for gas transmission pipelines located in High Consequence Areas (HCAs). These requirements have been incorporated into 49 Code of Federal Regulations (CFR) Part 192, Subpart “O”.
The pipeline integrity regulation mandates that an operator develop and maintain an Integrity Management Plan (IMP) that addresses regulatory requirements. The IMP is a systematic and comprehensive program designed to provide information to effectively allocate resources for the appropriate prevention, detection and mitigation activities needed to improve pipeline safety.
The IMP applies to DOT regulated natural gas transmission pipelines that coincide with High Consequence Areas. These pipelines are typically larger diameter (6” to 36”) steel pipe; operating at pressures from 60 psig to over 1000 psig. High Consequence Areas are defined as areas in close proximity to a DOT pipeline that contain high population density and/or “identified sites” (known facilities housing people with limited or impaired mobility such as hospital, school, prison, recreation areas, etc).
Statutory requirements for an integrity program include conducting baseline and reassessment testing of each covered transmission pipeline segment at specified intervals, conducting an integrated data analysis on a continuing basis, taking actions to address integrity concerns, addressing issues raised by PHMSA/OPS and by state (California Public Utilities Commission) and local authorities, conducting testing in an environmentally appropriate manner, providing notification of changes to a program, and permitting a state or OPS agent access to the risk analysis and integrity management program.
Key elements of The Gas Company’s IMP include—
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 |
Additional program requirements include completion of the baseline assessment for the top 50% risk ranked HCA’s by December 17, 2007 and the remainder by December 17, 2012.
The Gas Company continues to make extensive efforts and allocate significant resources to safely and reliably operate its natural gas pipeline system. The additional requirements of the Pipeline Safety Act along with The Gas Company’s ongoing operations and maintenance procedures will help in providing the flow of clean, safe, and reliable energy for Southern California.
Updated 8/2010
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