Roles and Responsibilities within the Pipeline Safety Program

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Roles and Responsibilities within the Pipeline
Safety Program
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Overview

• Participation Requirements
• Regulatory Responsibility
• Personnel
• Inspection Compliance Program
• Failure Investigation and Safety Related
  Conditions
• Agency Program Performance

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State Participation Requirements

• Chapter 601, Title 49 of the US Code
• Section 60105 Certifications
• Adoption of federal safety standards
• Provide for the enforcement of each standard
  (Civil Action/Penalties)
• Agency authority to enforce Inspection,
  Maintenance and Administrative standards
  proscribed under Title 49

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State Participation Requirements

• 60105 Certifications (cont)
• Requires full cooperation during federal audits
  of pipeline safety program
• Maintain certain documentation for audit purposes

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State Participation Requirements

• Interstate Agent Agreement
• Obtained approval from OPS to assume inspection
  responsibilities

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State Participation Requirements

• Interstate Agent Agreement
• Obtained approval from OPS to assume inspection
  responsibilities
• Prepare and submit annual work plan

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State Participation Requirements

• Interstate Agent Agreement
• Obtained approval from OPS to assume inspection
  responsibilities
• Prepare and submit annual work plan
• Follow OPS guidelines for conducting inspections,
  investigations, preparing reports

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State Participation Requirements

• Interstate Agent Agreement
• Obtained approval from OPS to assume inspection
  responsibilities
• Prepare and submit annual work plan
• Follow internal OPS guidelines for conducting
  inspections, investigations, preparing reports,
  maintaining records
• Perform other duties on behalf of and in
  partnership with OPS

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State Regulatory Responsibility

• Adoption of Federal Regulations and Requirements
• Waiver of Federal Regulations
• Interstate facilities considered by OPS in
  consultation with interstate agent
• For intrastate facilities, state must make
  notification to OPS of each waiver granted
• Final approval by OPS

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Personnel

• Individual Qualifications (Recommended)
• Experience in Pipeline Operations and/or,
• Engineering background or related technical
  fields
• May hire individuals with less then minimum
  qualifications

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Personnel

• Individual Qualifications (cont)
• Program Manager should be knowledgeable of
  pipeline safety technology, enforcement
  applications, and administrative procedures.
• Develop a love for Oklahoma City

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Personnel

• Agency Staffing Levels
• Must maintain adequate number of safety
  inspectors
• Number determined by staffing formula and other
  considerations
• OPS required to report to Congress qualification
  and staffing numbers annually.

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Personnel

• Allocation of Effort
• Each full-time inspector must devote a minimum of
  85 field inspection days related to compliance
  activities
• Reviewed during annual program evaluation

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Personnel

• Training
• Transportation Safety Institute
• Develops and conducts courses related to
  enforcement of pipeline safety regulations
• 16 courses (combined program)
• 14 CBT modules (Prerequisites)
• Completion within 3 yrs

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Personnel

• Training (cont)
• 2 courses (Integrity Management)
• 6 CBT modules (Prerequisites for Gas IM)
• List continues to expand

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Personnel

• Continuing Education
• Industry Sponsored
• NACE
• NTSB
• 40 hr HAZWOPR

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Inspection Compliance Program

• Inspection
• Should be conducted in a positive, constructive,
  and comprehensive manner
• Effectiveness of program efforts
• Quality of information obtained through
  inspections
• Evaluation of operator compliance

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Inspection Compliance Program

• Inspection
• Develop and maintain a written plan for the
  pipeline safety program containing six elements
• Operator Data

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Inspection Compliance Program

• Inspection
• Develop and maintain a written plan for its
  pipeline safety program containing six elements
• Operator Data
• Determining inspection priorities (scheduling)

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Inspection Compliance Program

• Inspection
• Develop and maintain a written plan for its
  pipeline safety program containing six elements
• Operator Data
• Determining inspection priorities (scheduling)
• Provide for methodical, systematic,
  comprehensive, and consistent inspections

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Inspection Compliance Program

• Types of Inspections
• Standard

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Inspection Compliance Program

• Standard Inspection (Preliminary work)
• Make contact and schedule dates
• Review OM procedures, plans, and programs
• Review inspection history
• Annual reports
• Pre-inspection field check

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Inspection Compliance Program

• Standard Inspection (Post inspection)
• Follow up (records other issues)
• Brief Director Sr. Eng on inspection findings
• Conduct exit interview
• Prepare inspection documentation correspondence
  for administrative review

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Inspection Compliance Program

• Types of Inspections
• Standard
• Specialized

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Inspection Compliance Program

• Specialized (Focused Subject Matter)
• Integrity Management
• Failure/Incident Investigation
• Operator Qualification
• Drug Alcohol
• Compliance w/CAO

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Inspection Compliance Program

• Specialized (cont)
• Whistleblower Complaints
• Waiver Requests
• Follow-up
• On-site Training

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Inspection Compliance Program

• Specialized
• Design, Testing and Construction
• New Construction Replacement Projects
• Integrity Assessments
• Anomaly Digs
• Repairs

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Inspection Compliance Program

• Inspection
• Develop and maintain a written plan for its
  pipeline safety program containing six elements
• Operator Data
• Determining inspection priorities (scheduling)
• Provide for methodical, systematic,
  comprehensive, and consistent inspections
• Notifying operator when noncompliance is
  identified

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Inspection Compliance Program

• Inspection
• Develop and maintain a written plan for its
  pipeline safety program containing six elements
• Operator Data
• Determining inspection priorities (scheduling)
• Provide for methodical, systematic,
  comprehensive, and consistent inspections
• Notifying operator when noncompliance is
  identified
• Conducting follow-up inspections

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Inspection Compliance Program

• Inspection
• Develop and maintain a written plan for its
  pipeline safety program containing six elements
• Operator Data
• Determining inspection priorities (scheduling)
• Provide for methodical, systematic,
  comprehensive, and consistent inspections
• Notifying operator when noncompliance is
  identified
• Conducting follow-up inspections
• Record keeping

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Failure Investigation Safety Related Conditions

• Investigation of Failures
• Reportable or significant incidents
• Primary objective
• To minimize the possibility of recurrence
• Institute enforcement action (if non-compliance
  identified)

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Failure Investigation Safety Related Conditions

• Investigation of Failures
• Notification of Incidents
• Pipeline Notification Number
• National Response Center (via OPS)

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Failure Investigation Safety Related Conditions

• Investigation of Failures
• Jurisdictional Responsibility
• Intrastate Facilities (State has sole authority)
• OPS may observe/assist
• Interstate Facilities (Cooperative Effort)
• OPS responsible for investigating (RD may
  delegate authority to State agency)
• PHMSA NTSB MOU
• Interstate facilities (NTSB)
• Intrastate facilities (Authority concurrent
  between state agency and NTSB)

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Failure Investigation Safety Related Conditions

• Safety Related Conditions
• Reports must be filed if.
• SRC cannot be corrected within 5 working days of
  determining a condition exists
• But no later than 10 working days after discovery
• Reports by state agency (every 30 days) until
  condition closed

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State Agency Program Performance

• Methods used to assess performance
• Certification/Agreement Attachments
• Determines compliance with program requirements
• Annual Program Evaluation
• Determines performance

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State Agency Program Performance

• Certification/Agreement Attachments
• State agency responds to questions regarding its
  compliance with various performance criteria
• Criteria used to assign points for allocating
  grant funds

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State Agency Program Performance

• Certification/Agreement Attachments
• Criteria
• State Jurisdiction and Agent Status
• Total State Field Inspection Activity
• Facilities Subject to State Safety Jurisdiction
• Pipeline Incidents
• State Compliance Actions

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State Agency Program Performance

• Certification/Agreement Attachments
• Criteria (cont)
• Record Maintenance and Reporting
• Employees Directly Involved in Pipeline Safety
  Program
• Compliance with Federal Requirements
• Certification Regarding Drug-Free Workplace

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State Agency Program Performance

• Annual Program Evaluation
• Conducted by OPS-Western Region
• Verifys certification/agreement attachments
• Record Review
• Field Inspection
• Verbal Performance review at conclusion
• Letter to Commission Chair
• Response back to RD within 45 days

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And then the process starts all over again

• Questions?