# Gas Integrity Management Enforcement Guidance - **operation:** document - **citation:** PHMSA Guidance, Gas Integrity Management Enforcement Guidance - **title:** Gas Integrity Management Enforcement Guidance - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2015-12-07 - **effective on:** 2015-12-07 - **summary:** Gas Integrity Management Enforcement Guidance Document Gas_Integrity_Management_Enforcement_Guidance_12_7_2015.pdf (1.76 MB) The materials contained in this document consist of guidance, techniques, procedures and other information for internal use by the PHMSA pipeline safety enforcement staff. This guidance document describes the practices used by PHMSA pipeline safety investigators and other enforcement personnel - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-guidance-gas-integrity-management-enforcement-guidance-2e8eadbe.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-guidance-gas-integrity-management-enforcement-guidance-2e8eadbe.md - **app url:** https://regulus.evalyn.ai/document/phmsa-guidance-gas-integrity-management-enforcement-guidance-2e8eadbe - **source url:** https://www.phmsa.dot.gov/pipeline/enforcement/gas-integrity-management-enforcement-guidance **body:** Gas Integrity Management Enforcement Guidance Document Gas_Integrity_Management_Enforcement_Guidance_12_7_2015.pdf (1.76 MB) The materials contained in this document consist of guidance, techniques, procedures and other information for internal use by the PHMSA pipeline safety enforcement staff. This guidance document describes the practices used by PHMSA pipeline safety investigators and other enforcement personnel in undertaking their compliance, inspection, and enforcement activities. Issued Date: Monday, December 7, 2015 <<>> Gas Transmission Integrity Management Enforcement Guidance Sections 192.901 through 192.951 Introduction The materials contained in this document consist of guidance, techniques, procedures and other information for internal use by the PHMSA pipeline safety enforcement staff. This guidance document describes the practices used by PHMSA pipeline safety investigators and other enforcement personnel in undertaking their compliance, inspection, and enforcement activities. This document is U.S. Government property and is to be used in conjunction with official duties. The Federal pipeline safety regulations (49 CFR Parts 190-199) discussed in this guidance document contains legally binding requirements. This document is not a regulation and creates no new legal obligations. The regulation is controlling. The materials in this document are explanatory in nature and reflect PHMSA’s current application of the regulations in effect at the time of the issuance of the guidance. In preparing an enforcement action alleging a probable violation, an allegation must always be based on the failure to take a required action (or taking a prohibited action) that is set forth directly in the language of the regulation. An allegation should never be drafted in a manner that says the operator “violated the guidance.” Nothing in this guidance document is intended to diminish or otherwise affect the authority of PHMSA to carry out its statutory, regulatory or other official functions or to commit PHMSA to taking any action that is subject to its discretion. Nothing in this document is intended to and does not create any legal or equitable right or benefit, substantive or procedural, enforceable at law by any person or organization against PHMSA, its personnel, State agencies or officers carrying out programs authorized under Federal law. Decisions about specific investigations and enforcement cases are made according to the specific facts and circumstances at hand. Investigations and compliance determinations often require careful legal and technical analysis of complicated issues. Although this guidance document serves as a reference for the staff responsible for investigations and enforcement, no set of procedures or policies can replace the need for active and ongoing consultation with supervisors, colleagues, and the Office of Chief Counsel in enforcement matters. Comments and suggestions for future changes and additions to this guidance document are invited and should be forwarded to your supervisor. The materials in this guidance document may be modified or revoked without prior notice by PHMSA management. i <<>> Table of Contents Glossary .................................................................................................................................iv §192.901.................................................................................................................................1 §192.903.................................................................................................................................4 §192.905.................................................................................................................................9 §192.907(a) ............................................................................................................................15 §192.907(b) ............................................................................................................................19 §192.909.................................................................................................................................21 §192.911.................................................................................................................................24 §192.913.................................................................................................................................29 §192.915.................................................................................................................................33 §192.917(a) ............................................................................................................................36 §192.917(b) ............................................................................................................................42 §192.917(c) ............................................................................................................................48 §192.917(d) ............................................................................................................................54 §192.917(e) ............................................................................................................................57 §192.919.................................................................................................................................63 §192.921(a) ............................................................................................................................68 §192.921(b) ............................................................................................................................73 §192.921(c) ............................................................................................................................76 §192.921(d) ............................................................................................................................80 §192.921(e) ............................................................................................................................83 §192.921(f) .............................................................................................................................86 §192.921(g) ............................................................................................................................89 §192.921(h) ............................................................................................................................92 §192.923.................................................................................................................................95 §192.925(a) & (b) ...................................................................................................................97 §192.925(b)(1) .......................................................................................................................100 §192.925(b)(2) .......................................................................................................................106 §192.925(b)(3) .......................................................................................................................111 §192.925(b)(4) .......................................................................................................................116 §192.927(a) & (b) ...................................................................................................................120 §192.927(c)(1) ........................................................................................................................124 ii <<>> §192.927(c)(2) ....................................................................................................................... 128 §192.927(c)(3) ...................................................................................................................... 131 §192.927(c)(4) ....................................................................................................................... 135 §192.927(c)(5) ....................................................................................................................... 139 §192.929.................................................................................................................................142 §192.931.................................................................................................................................146 §192.933(a) ........................................................................................................................... 149 §192.933(b) & (c) .................................................................................................................. 153 §192.933(d) ........................................................................................................................... 157 §192.935(a) ........................................................................................................................... 162 §192.935(b) ........................................................................................................................... 166 §192.935(c) ........................................................................................................................... 171 §192.935(d) ........................................................................................................................... 173 §192.935(e) ........................................................................................................................... 177 §192.937(a) & (b) .................................................................................................................. 180 §192.937(c) ........................................................................................................................... 186 §192.939(a) ........................................................................................................................... 190 §192.939(b) ........................................................................................................................... 195 §192.941(a) ........................................................................................................................... 200 §192.941(b) ........................................................................................................................... 202 §192.941(c) ........................................................................................................................... 205 §192.943.................................................................................................................................208 §192.945.................................................................................................................................211 §192.947.................................................................................................................................216 §192.949.................................................................................................................................219 §192.951.................................................................................................................................222 3 <<>> Glossary For a complete “Glossary of Terms” please refer to the following link: http://www.phmsa.dot.gov/staticfiles/PHMSA/Pipeline/TQGlossary/Glossary .html 4 <<>> Enforcement Guidance Revision Date Code Section Section Title Existing Code Language Origin of Code Last Amendment Interpretation Summaries Advisory Bulletin/Alert Notice Summaries Other Reference Material & Source Part 192, Gas Transmission Pipeline Integrity Management 12/7/2015 §192.901 What do the regulations in this subpart cover? This subpart prescribes minimum requirements for an integrity management program on any gas transmission pipeline covered under this part. For gas transmission pipelines constructed of plastic, only the requirements in §§192.917, 192.921, 192.935 and 192.937 apply. Amdt. 192-95, 68 FR 69778, December 15, 2003 Amdt. 192-95A, 69 FR 9307, December 20, 2003 Advisory Bulletin ADB -12-03 Notice to Operators of Driscopipe 8000 High Density Polyethylene Pipe of the Potential for Material Degradation On March 6, 2012, PHMSA issued this advisory bulletin to alert operators using Driscopipe® 8000 High Density Polyethylene Pipe (Drisco8000) of the potential for material degradation. Degradation has been identified on pipe between one-half inch to two inches in diameter that was installed between 1978 and 1999 in desert-like environments in the southwestern United States. However, since root causes of the degradation have not been determined, PHMSA cannot say with certainty that this issue is isolated to these regions, operating environments, pipe sizes, or pipe installation dates. While the manufacturer has attempted to communicate with known or suspected users, PHMSA and the National Association of Pipeline Safety Representatives (NAPSR) have identified several operators currently using Drisco 8000 pipe who had not received communications about the issue. PHMSA is issuing this advisory bulletin to all operators of Drisco 8000 pipe in an effort to ensure they are aware of the issue, communicating with the manufacturer and their respective regulatory authorities to determine if their systems are susceptible to similar degradation, and taking measures to address it. ASME B31.8S-2004, Supplement to B31.8 on Managing System Integrity of Gas Pipelines Gas Piping Technology Committee (GPTC) Part 192, Appendix E.I §192.901 Page 1 <<>> Guidance Information Examples of a Probable Violation or Inadequate Procedures PHMSA Gas Transmission Integrity Management FAQs: 2 Who must comply with the rule? 3 Does the rule apply to operators of transmission pipelines for gases other than natural gas? 7 Do the requirements of the rule apply to "idle" pipe? 9 Does the rule apply to gathering and other low-stress lines? 84 The Integrity Management Program portion of the rule [192.907] applies to all portions of a pipeline system that are in HCAs, including compressor stations, metering stations, and other equipment. What must an operator do to comply with the rule for these facilities? 150 What requirements must an operator meet if there are no high consequence areas on any of its transmission pipelines? 188 Are jurisdictional gathering lines covered? 247 For plastic transmission pipeline, must I meet all of the requirements in the sections specified in section 192.901 or just those requirements specifically directed at plastic pipe? 1. The requirements of Subpart O apply to all gas transmission pipelines including compressor stations, metering stations, regulator stations, valve sets, and other fabricated assemblies. 2. All requirements of Subpart O apply to “line pipe.” 3. For pipeline facilities other than “line pipe,” an assessment may not necessarily be required. 4. Plastic transmission pipelines must be included in an integrity management program. The Preamble of the Federal Register notes that most of the requirements are applicable to metal pipelines, not plastic, only certain requirements apply to plastic gas transmission pipelines. Requirements for a continuing threat analysis (§§192.917, 192.937), a baseline assessment if a threat other than third-party damage is identified (§192.921), and additional preventive and mitigative measures (§192.935) apply to plastic gas transmission pipelines. (Federal Register / Vol. 68, No. 240 / Monday, December 15, 2003 / Rules and Regulations at Page 69801.)Failure to have procedures to address this Integrity Management element should be cited under the appropriate paragraph of §192.911 1. Failure to apply Subpart O requirements to all of the pipelines or components covered under the Subpart. Since 192.901 solely involves subpart scope, there are no requirements that can be violated, however cross referencing of this regulation is acceptable when citing other regulation for failure to apply requirements to pipelines or components. 2. Failure to include plastic gas transmission pipe in their Integrity Management Program. Depending on the circumstances, some of the examples listed in this section may be inadequate plans and procedures, and not probable violations. Thus, the enforcement tool to address these issues would be a Notice of Amendment and not a Notice of Probable Violation or a Warning Letter. Section 3 of the Enforcement Procedures provides guidance on selecting the appropriate enforcement action. §192.901 Page 2 <<>> Examples of Evidence 1. Integrity Management Plan or Program, or applicable portion that shows an omission or deficiency in the Plan or Program. 2. Records. 3. Documented conversations with operator or contractor personnel identifying inconsistencies or problems regarding implementation of the IM program. Other Special Notations §192.901 Page 3 <<>> Enforcement Part 192 Gas Transmission Pipeline Integrity Management Guidance Revision Date 12/7/2015 Code Section §192.903 Section Title What definitions apply to this subpart? Existing Code Language The following definitions apply to this subpart: Assessment is the use of testing techniques as allowed in this subpart to ascertain the condition of a covered pipeline segment. Confirmatory direct assessment is an integrity assessment method using more focused application of the principles and techniques of direct assessment to identify internal and external corrosion in a covered transmission pipeline segment. Covered segment or covered pipeline segment means a segment of gas transmission pipeline located in a high consequence area. The terms gas and transmission line are defined in §192.3. Direct assessment is an integrity assessment method that utilizes a process to evaluate certain threats (i.e., external corrosion, internal corrosion and stress corrosion cracking) to a covered pipeline segment's integrity. The process includes the gathering and integration of risk factor data, indirect examination or analysis to identify areas of suspected corrosion, direct examination of the pipeline in these areas, and post assessment evaluation. High consequence area means an area established by one of the methods described in paragraphs (1) or (2) as follows: (1) An area defined as- (i) A Class 3 location under §192.5; or (ii) A Class 4 location under §192.5; or (iii) Any area in a Class 1 or Class 2 location where the potential impact radius is greater than 660 feet (200 meters), and the area within a potential impact circle contains 20 or more buildings intended for human occupancy; or (iv) Any area in a Class 1 or Class 2 location where the potential impact circle contains an identified site. (2) The area within a potential impact circle containing- (i) 20 or more buildings intended for human occupancy, unless the exception in paragraph (4) applies; or (ii) An identified site. (3) Where a potential impact circle is calculated under either method (1) or (2) to establish a high consequence area, the length of the high consequence area extends axially along the length of the pipeline from the outermost edge of the first potential impact circle that contains either an identified site or 20 or more buildings intended for human occupancy to the outermost edge of the last contiguous potential impact circle that §192.903 Page 4 <<>> contains either an identified site or 20 or more buildings intended for human occupancy. (See Figure E.I.A. in Appendix E.) (4) If in identifying a high consequence area under paragraph (1)(iii) of this definition or paragraph (2)(i) of this definition, the radius of the potential impact circle is greater than 660 feet (200 meters), the operator may identify a high consequence area based on a prorated number of buildings intended for human occupancy with a distance of 660 feet (200 meters) from the centerline of the pipeline until December 17, 2006. If an operator chooses this approach, the operator must prorate the number of buildings intended for human occupancy based on the ratio of an area with a radius of 660 feet (200 meters) to the area of the potential impact circle (i.e., the prorated number of buildings intended for human occupancy is equal to 20 x (660 feet) [or 200 meters]/potential impact radius in feet [or meters]**2). Identified site means each of the following areas: (a) An outside area or open structure that is occupied by twenty (20) or more persons on at least 50 days in any twelve (12)-month period. (The days need not be consecutive.) Examples include but are not limited to, beaches, playgrounds, recreational facilities, camping grounds, outdoor theaters, stadiums, recreational areas near a body of water, or areas outside a rural building such as a religious facility; or (b) A building that is occupied by twenty (20) or more persons on at least five (5) days a week for ten (10) weeks in any twelve (12)- month period. (The days and weeks need not be consecutive.) Examples include, but are not limited to, religious facilities, office buildings, community centers, general stores, 4-H facilities, or roller skating rinks; or (c) A facility occupied by persons who are confined, are of impaired mobility, or would be difficult to evacuate. Examples include but are not limited to hospitals, prisons, schools, day-care facilities, retirement facilities or assisted-living facilities. Potential impact circle is a circle of radius equal to the potential impact radius (PIR). Potential impact radius (PIR) means the radius of a circle within which the potential failure of a pipeline could have significant impact on people or property. PIR is determined by the formula r = 0.69* (square root of (p*d \2\)), where `r' is the radius of a circular area in feet surrounding the point of failure, `p' is the maximum allowable operating pressure (MAOP) in the pipeline segment in pounds per square inch and `d' is the nominal diameter of the pipeline in inches. Note: 0.69 is the factor for natural gas. This number will vary for other gases depending upon their heat of combustion. An operator transporting gas other than natural gas must use section 3.2 of ASME/ANSI B31.8S-2001 (Supplement to ASME B31.8; incorporated by reference, see §192.7) to calculate the impact radius formula. §192.903 Page 5 <<>> Origin of Code Last Amendment Interpretation Summaries Advisory Bulletin/Alert Notice Summaries Remediation is a repair or mitigation activity an operator takes on a covered segment to limit or reduce the probability of an undesired event occurring or the expected consequences from the event. Amdt. 192-95, 68 FR 69778, December 15, 2003 Amdt. 192-103A, 72 FR 4655, February 1, 2007 Interpretation: WINDOT 192.903 1 Date: 08-15-2008 "Should the property boundary of a golf course be considered as a 'recreational facility' and therefore an identified site? It is our intention to only count golf course boundaries as identified sites where they are occupied by 20 or more persons within the PIR [potential impact radius] at one time for at least 50 days in any 12 month period. Is this an acceptable interpretation of the rule with regard to golf courses?" The gas integrity management program (IMP) rules are intended to protect identified sites occupied by 20 or more persons for specified periods. While it is possible for 20 or more persons to congregate near the boundary of a golf course inside a pipeline's PIR, these persons would likely be in transit and cannot truly be said to "occupy" the area as intended by the regulations. Therefore, such a location would not be an identified site per §192.903. PHMSA does not recommend using a golf course boundary to define an identified site because the boundary, in and of itself, is of little value. Instead, we recommend looking for sites such as a clubhouse, practice greens, or combinations of sites, such as a putting green near a tee box, to find areas on a golf course that are occupied by 20 or more persons for the specified periods. These could be identified sites. Advisory Bulletin ADB-03-03 Identified sites for possible inclusion as high consequence areas (HCAs) in gas integrity management programs. On August 6, 2002, RSPA/OPS published a final rule on how to identify the populated areas near a pipeline for which additional protections would be required (67 FR 50824). These “high consequence areas” (HCAs) include not only population areas already identified by pipeline operators through the longstanding Class location definitions, but also “identified sites,” 49 CFR 192.761(f). Inclusion of identified sites is intended to pick up isolated population areas which are not picked up through the Class location process. These could include isolated nursing homes, schools, and campgrounds that may be close enough to the pipeline to be at risk should there be a pipeline failure. Commenters expressed concerns that what was intended to be a relatively simple task, identifying certain sites as high consequence areas, could become a never-ending search. RSPA/OPS is providing guidance in this advisory bulletin to provide the necessary clarification. With this guidance, operators can identify sites in preparation for required assessments and integrity management programs. The public will receive the assurance that the search for “identified sites” for inclusion in integrity management programs is clearly understood and thorough. The advisory bulletin provides guidance on a good faith effort in conducting this search. §192.903 Page 6 <<>> Other Reference Material & Source ASME B31.8S-2004, Supplement to B31.8 on Managing System Integrity of Gas Pipelines, Section 3 Gas Piping Technology Committee (GPTC) Part 192, Appendix E.I TTO-13, Potential Impact Radius Formulae for Flammable Gases Other Than Natural Gas Subject to 49 CFR 192, June 2005 TTO-14, Derivation of Potential Impact Radius Formulae for Vapor Cloud Dispersion Subject to 49 CFR 192, January 2005 PHMSA Gas Transmission Integrity Management FAQs: 17 What is an identified site? 119 Can I use normal operating pressure in my potential impact circle calculations if that pressure is significantly below MAOP? 144 What is the preferred method for calculating the Potential Impact Radius (PIR) of a leak of a non-flammable gas within the context of Pipeline Integrity Management? The regulation refers to ASME B31.8S-2004 Section 3.2 for calculation of PIR for gases other than natural gas. However, this document only deals with flammable gases. ASME B31.8S-2004 allows alternate models to be used for calculating impact radius, but provides no guidance as to preferred methods of modeling non-flammable or corrosive gases. 208 Is the derivation of the PIR equation publicly available? 211 What is the time period for the 20 persons in an area? 20 people for 10 min/day, 20 people for 2 hours/day, 20 people for 8 hours/day? Guidance Information 1. Definitions included in IM plans must be consistent with those found in §192.903. 2. The formula for calculation of the potential impact radius must be consistent with 192.903 requirements [r = 0.69* (square root of (p*d \2\))] and the pressure used in the formula must be based on maximum allowable operating pressure (MAOP). 3. Equation for PIR can only be used for flammable gas. The factor (0.69) may vary according to the flammability of the actual gas compositions (see TTO- 13 or ASME B31.8S-2004, Section 3.2). 4. Failure to have procedures to address this Integrity Management element should be cited under the appropriate paragraph of §192.911. 5. Selected Final orders referencing §192.903 a) Indiana Gas Co. Inc., [2-2007-1014], (July 15, 2010), Item 2B, Operator failed to ensure that accurate maximum allowable operating pressures were used to determine the potential impact radius. §192.903 Page 7 <<>> Examples of a Probable Violation or Inadequate Procedures 1. Definitions are not consistent with Part 192. 2. Records do not demonstrate the proper factor (i.e. - .69 for pipeline quality natural gas) for calculating potential impact radius was used. 3. MAOP was not used to calculate the PIR. Depending on the circumstances, some of the examples listed in this section may be inadequate plans and procedures, and not probable violations. Thus, the enforcement tool to address these issues would be a Notice of Amendment and not a Notice of Probable Violation or a Warning Letter. Section 3 of the Enforcement Procedures provides guidance on selecting the appropriate enforcement action. Examples of Evidence 1. Integrity Management Plan or Program, or applicable portion that shows an omission or deficiency in the Plan or Program. 2. Records. 3. Formula for calculating PIR. 4. Records of product being transported. 5. Documented conversations with operator or contractor personnel. 6. Documented conversations with operator or contractor personnel identifying inconsistencies or problems regarding IM definitions. Other Special Notations §192.903 Page 8 <<>> Enforcement Part 192 Gas Transmission Pipeline Integrity Management Guidance Revision Date 12/7/2015 Code Section §192.905 Section Title How does an operator identify a high consequence area? Existing Code Language (a) General. To determine which segments of an operator's transmission pipeline system are covered by this subpart, an operator must identify the high consequence areas. An operator must use method (1) or (2) from the definition in §192.903 to identify a high consequence area. An operator may apply one method to its entire pipeline system, or an operator may apply one method to individual portions of the pipeline system. An operator must describe in its integrity management program which method it is applying to each portion of the operator's pipeline system. The description must include the potential impact radius when utilized to establish a high consequence area. (See appendix E.I. for guidance on identifying high consequence areas.) (b)(1) Identified sites. An operator must identify an identified site, for purposes of this subpart, from information the operator has obtained from routine operation and maintenance activities and from public officials with safety or emergency response or planning responsibilities who indicate to the operator that they know of locations that meet the identified site criteria. These public officials could include officials on a local emergency planning commission or relevant Native American tribal officials. (2) If a public official with safety or emergency response or planning responsibilities informs an operator that it does not have the information to identify an identified site, the operator must use one of the following sources, as appropriate, to identify these sites. (i) Visible marking (e.g., a sign); or (ii) The site is licensed or registered by a Federal, State, or local government agency; or (iii) The site is on a list (including a list on an internet web site) or map maintained by or available from a Federal, State, or local government agency and available to the general public. (c) Newly identified areas. When an operator has information that the area around a pipeline segment not previously identified as a high consequence area could satisfy any of the definitions in §192.903, the operator must complete the evaluation using method (1) or (2). If the segment is determined to meet the definition as a high consequence area, it must be incorporated into the operator's baseline assessment plan as a high consequence area within one year from the date the area is identified. Origin of Code Amdt. 192-95, 68 FR 69778, December 15, 2003 Last Amendment §192.905 Page 9 <<>> Interpretation Summaries Advisory Bulletin/Alert Notice Summaries Other Reference Material & Source Advisory Bulletin ADB-03-03 Identified sites for possible inclusion as high consequence areas (HCAs) in gas integrity management programs. On August 6, 2002, RSPA/OPS published a final rule on how to identify the populated areas near a pipeline for which additional protections would be required (67 FR 50824). These “high consequence areas” (HCAs) include not only population areas already identified by pipeline operators through the longstanding Class location definitions, but also “identified sites,” 49 CFR 192.761(f). Inclusion of identified sites is intended to pick up isolated population areas which are not picked up through the Class location process. These could include isolated nursing homes, schools, and campgrounds that may be close enough to the pipeline to be at risk should there be a pipeline failure. Commenters expressed concerns that what was intended to be a relatively simple task, identifying certain sites as high consequence areas, could become a never-ending search. RSPA/OPS is providing guidance in this advisory bulletin to provide the necessary clarification. With this guidance, operators can identify sites in preparation for required assessments and integrity management programs. The public will receive the assurance that the search for “identified sites” for inclusion in integrity management programs is clearly understood and thorough. The advisory bulletin provides guidance on a good faith effort in conducting this search. ASME B31.8S-2004, Supplement to B31.8 on Managing System Integrity of Gas Pipelines, Section 3 Part 192, Appendix E.I Supplemental Guidance Appendix A.01, Protocol Guidance for the Identification of High Consequence Areas. PHMSA Gas Transmission Integrity Management FAQs: 17 What is an identified site? 18 Are there practical limits on an operator’s search for identified sites? 19 What are OPS expectations for operators to determine new or changed HCAs? 20 When must newly-identified HCAs be included in the program? 117 How often must an operator update its building density survey and list of identified sites to determine if new HCAs have been created? 120 Who is an appropriate safety authority for locating identified sites? 143 When determining "identified sites", does one have to consider standing traffic on roads/expressways under the "outside area or open structure" portion of the definition? If so, is there any guidance on how many people per vehicle should be used to compute the total of 20? 170 Must an operator continue to contact public safety officials in order to locate identified sites even if they don’t respond? §192.905 Page 10 <<>> 176 Is a single home housing a disabled person considered an identified site? 191 If a pipeline is determined to fall within an HCA due to its class location, does the operator also have to identify identified sites? 195 How were the Fire Marshals notified of providing assistance in locating identified sites? Is there written communication (i.e., documentation) that operators can reference? 233 Does growth of an existing HCA, which introduces new length of pipeline segment into the HCA, constitute a "newly-identified HCA?" Guidance Information 1. The §192.903 definitions provided are to determine identified sites that may be considered an HCA for a specific pipeline operator as the regulations for 192.905 are applied. 2. Each operator should have maps of their pipelines systems along with identified HCA’s along the pipeline route. The operator must use system maps or other suitably detailed means to identify pipeline segment locations that are located in high consequence areas. 3. The operator's process must describe how to implement methods (1) and/or (2) in order to identify high consequence areas (HCAs). The operator's must document the method used for each portion of the pipeline system. 4. The operator must periodically look for changes along its pipeline to identify new HCAs. Additionally, those with no IM Program must continually take measures to look for new HCAs along their pipelines. 5. Operators were allowed to pro rate house counts in determining whether an HCA area existed. The time frame for this expired in December 2006 and prorating is no longer allowed. 6. Failure to have a process/procedure to identify HCAs or having an inadequate process describing how to apply Method 1 or 2 should be cited under §192.911(a). 7. Selected Final Orders Referencing §192.905: a) Mardi Gras Pipeline, LLC, [4-2009-1007], (December 19, 2011), Item 1, Operator failed to properly identify those segments of its gas transmission pipeline system that constituted HCAs. b) Mardi Gras Pipeline, LLC, [4-2009-1007], (December 19, 2011), Item 2, Operator failed to use public officials as a resource in the identification of areas that would qualify as “identified sites” within the potential impact radius along the pipeline. c) Northwest Pipeline Corp., [5-2007-1001], (May 2, 2011), Item 1, Operator failed to describe and document in its IMP which method it had applied to each portion of its pipeline system to identify HCAs. The operator also failed to maintain records to support any decision, analysis or process developed and used to implement its IMP. Specifically, it alleged that the operator failed to keep documents supporting the process(es) that had been used to identify each HCA segment. §192.905 Page 11 <<>> d) Northwest Pipeline Corp., [5-2007-1001], (May 2, 2011), Item 2A, Operator failed to describe in its IMP which method it had applied to each portion of its pipeline to identify HCA segments. Specifically, the system maps and the Geographic Information System (GIS) used by the operator failed to establish a suitable means of documenting segment locations in HCAs. e) Northwest Pipeline Corp., [5-2007-1001], (May 2, 2011), Item 2B, Operator failed to use certain information available to it in cases where public officials with safety or emergency response or planning responsibilities had informed the company that they did not have information delineating identified sites. Specifically, the operator had failed, by December 17, 2004,to use visible markings, licensing or registration by a governmental agency, or listing on the Internet or other public available maps maintained by governmental entities to delineate identified sites in lieu of obtaining relevant information from public officials. Also, the operator did not have procedures on how it located identified sites using such alternative sources of information. f) Northwest Pipeline Corp., [5-2007-1001], (May 2, 2011), Item 4, Operator failed to properly identify HCA areas using one of the methods described in paragraph (1) or (2) of §192.903. There were four separate violations: Item 4A, Operator failed to properly apply Method 1 in delineating HCAs, insofar as the full length of Class 3 and 4 locations was not included in the HCAs. Item 4B, Operator failed to properly identify HCA areas using Method 1 under §192.903. Specifically, the operator failed to properly identify HCAs under portion of Method 1 which calls for the identification of areas “in a Class 1 or 2 location where the potential impact circle contains an identified site”. Documentation reviewed during the inspection showed identified sites on the operator’s Transco system that the company had failed to include in HCAs. The HCA identification process was flawed insofar as the company’s field personnel were not even trained in the HCA identification process until well after December 17, 2004. Item 4C, Operator failed to properly identify HCA areas using Method 1. Specifically, the operator defined the term “day” as a continuous 8 hour period, for purposes of determining whether structures or outdoor areas qualified as identified sites. This definition was inconsistent with the regulation, insofar as the 20 or more persons criterion applied to the presence of people at a particular location at any point in time. Item 4D, Operator failed to properly - **truncated:** true - **body characters:** 514652