Compliance Inspections -Attachment 11 - DOT Compliance Quality Assurance Auditing Procedure

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Attachment 1 I

DOT COMPLIANCE QUALITY ASSURANCE AUDITING PROCE. . ._

TABLE OF CONTENTS

TAB A GENERAL FILES PROCEDURE

Emergency Plans ..................................................................................................... Page 1

Liaison with Public Officials .......................................................................... Page 1 Public Apprisement ......................................................................................... Page 1

Aerial Pipeline Patrol .............................................................................................. Page 2 Damage Prevention Program .................................................................................. Pag e 2 Leakage Surveys with Gas Detector ....................................................................... Page 3

Relief Valves: Capacity Calculations .................................................................... Pag e 4 Corrosion Control: Rectifiers, Critical Bonds. and Coupons ............................... Page 4

Training ............................................................................................................. ge 1

. . Odonzatmn .............................................................................................................. Page 3

LINE SPECIFIC FILES PROCEDURE TABB

Overpressure Protection: Mainline ........................................................................ Pag e 1 Mainline Relief Valves ................................................................................... Page 1 Mainline Regulators ........................................................................................ Page 1

Valves ...................................................................................................................... Page 2 Patrolling: (Also visual leakage survey) ................................................................ Page 3 Leaks, Damages and Failures ................................................................................... ge 4 Measurement: Relief Valves & Regulators ........................................................... Page 5 Corrosion Control: Annual Survey, Bell-Holes, Shorted Casings ........................ Page 5

TAB C CORROSION SURVEY CODES AND U L LIMITS . . Upperhwer Linuts ................................................................................................ Page 1

Annual Survey Codes .............................................................................................Pag e 2

AUDIT FORMS TAB D

General Files Check List (Form: CS99-0010) ............................................................ Page 1-3 Individual Pipeline Files Check List (Form: CS99-0020) .......................................... Page 1-3 Facility Audit Results (Form: CS9pO040) ................................................................. Page 1-2

TOC . Pipeline Revised: 24/99

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PIPELINE Quality Assurance Auditing Procedure General Files Procedure Page 1 - - .

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A S S T J R ~ AT-PROCEQUBE

-Pians (192.615 - O&M S ~ C . 501)

A.

B.

C.

Training

1.

2.

At least once each calendar year?

Documentation reflects that employees are knowledgeable of procedures and have demonstrated that the training is effwtive?

In an actual or simulated emergency, employees’ responses were reviewed to determine if the procedures were effectively followed?

Was training participative classroom instruction or an actual emergency simulation?

3.

4.

Liaison with public emergency services:

1. Liaison activities are performed at least once each calendar year, and include all emergency services that may be expected to respond?

2. The type of emergencies and plans for mutual assistance were discussed?

3. Protection of life and property were stressed?

Public apprisement: (Recognizing a P L emergency)

1. Documentation of visits and appropriate literature mail-outs or handouts to:

a) Public emergency organizations?

b) Public officials?

c)

d)

Landowners and residents near our pipelines?

Excavation - related personnel actually working in vicinity of our pipelines?

2. Group meetings attended by:

Tab 2-A -Pipeline General Files Revised: 2/4/99

PIPELINE Quality Assurance Auditing Procedure General Files Procedure

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a) Public officials?

Page 2

b) Public emergency personnel?

c) Excavators and Contractors?

d) Customers (distribution companies, etc ...) ?

e) Company personnel?

In which the recognition and reporting of gas pipeline emergencies is a topic of discussion?

Public apprisement program is conducted:

a)

b)

c) By group meetings annually?

3.

On a continuing basis? (ads, landowners, public)

In conjunction with liaison activities annually?

-: (192.705 - O&M S ~ C . 202.3) . . . A.

B.

C.

D.

E.

F.

Are all pipelines within the P/L District patrolled by air?

Ifnot, should they be?

What are the patrol fi-equencies?

Are indications of leaks, construction activity, and other factors Setting the safety and operation of the pipelines quickly related to operations personnel?

Are conditions such as soil erosion, exposed buried lines, damaged or missing line markers, etc., which could lead to a hazardous condition related to operations personnel in a timely manner?

Are responses and actions of operations personnel adequate, timely and documented?

PP -~"m: (192.614 - O&M S ~ C . 503) (for Class 3 locations with 46 or more buildings and all Class 4 locations)

A. Does the program provide or generate sufficient documentation of

1.

2.

A current list of excavators?

Periodic (annual) notification of those excavators?

Tab 2-A - Pipeline G e n d Files Revised: 2/4/99

PIPELINE Quality Assurance Auditing Procedure General Files Procedure Page 3

B.

C.

D.

E.

3.

4.

Does the content of notifications include information on learning the location of our pipelinds)?

Is a log of planned excavation notifications maintained and does it reflect.

1.

2.

Was onsite inspection provided for critical phases of construction in which the pipeline or coating could be damaged?

In the case of blasting, was a leakage survey performed, if warranted, following the blasting?

1. Visual?

2. Gas detector?

Periodic notification of the public in the vicinity of our pipeline(s)?

Methods, content and fkquency of notifications to excavators and the public?

Actual notifications to excavators that we have pipelines in the area?

Type and identity of temporary location markers placed prior to excavation?

*: (192.706 - O M S a . 202.4)

A. If required odorant levels verified at the same frequencies listed below or more often, is a leakage survey with a gas detector performed?

1. In Class 3 locations, at intervals not exceeding 7 112 months, but at least twice each calendar year?

2. In Class 4 locations, at intervals not exceeding 4 1/2 months, but at least four times each calendar year?

B. Are shorted casings surveys with gas detectors conducted:

1. In Class 1 and 2 locations, at intervals not exceeding 7 112 months, but at least twice each calendar year?

2. In Class 3 and 4 location, at intervals not exceeding 4 112 months, but at least four times each calendar year?

(192.625 - O&M Sec. 202.5) . . A. Odorization of gas in Class 3 and 4 locations

1. The combustible gas contains a natural odorant so that in a concentration in air of

Tab 2-A - Pipeline General Files Revised: 2/4/99

PIPELINE Quality Assurance Auditing Procedure General Files Procedure Page 4

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1/5 of the lower explosive limit, the gas is readily detectable by a person with a normal sense of smell

a) Verified at intervals of no more than 7 1/2 months and at least twice each calendar year in Class 3 locations; and, at intervals of no more than 4 1/2 months and at least four times each calendar year in Class 4 locations? and

b) Uses an odorometer?

2. Leakage suryeys are performed with gas detector - see Leakage Survey Section of auditing procedure.

B. Ifodorant is introduced into the gas stream, it must:

1. Not be harmfid or toxic to persons breathing the gas, or

2. Harmfid or corrosive to material and equipment, and

3. Not be soluble in water to an extent greater than 2.5 parts to 100 parts by weight, and

4. Be introduced at levels without wide variations

(192.739 & 743 - O&M S ~ C . 202.7)

A. Capacity calculations are made andlor reviewed at intervals not exceeding 15 months, but at least once each calendar year?

B. Relief capacity is suf€icient to prevent overpressuring of pipeline(s)?

- See Survey Codes and Limits Sheets (192.451 thru 491 - O&M Sec. 201.2)

A. Rectifiers and associated equipment

1. Are rectifier readings obtained and other power sources and associated equipment electrically checked and inspected at least six times each year at no more than 2 1/2 month intervak?

2. Are deficiencies corrected before the next inspection date?

3. Are problems and corrective measures documented or indicated?

B. Critical interference bonds - (where failure of the bond jeopardizes structure protection)

1. Are the bonds checked at least six times per year and within intervals of no more

Tab 2-A -Pipeline G e n d Files Revised: 2/4/99

* PIPELINE Quality Assurance Auditing Procedure General Files Procedure

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than 2 1/2 months?

C.

2. Are problems and comctive measures documented or indicated?

Internal coupons

Page 5

1. Is corrosive gas being transported? if so,

a) Has the effect of the gas on the pipeline been investigated? and,

b) What steps have been taken to minimize the intemal corrosion?

1) Corrosion inhibitor?

2) Dehydration?

2. Have internal coupons been installed to monitor the effectiveness of the corrosion-mitigating program? If so,

3. Are the coupons checked two times each calendar year at intervals not exceeding 7 1/2 months? and

4. Is the mil loss per year acceptable?

Tab 2-A - Pipeline General Files Revised: 2/4/99

PIPELINE Quality Assurance Auditing Procedure I < LINE SPECIFIC FaES Page 1

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Overpressure Protection: MAINLINE (192.739 & .743 - O M Sec. 202.7)

A. Mainline Relief Valves - Testing and Inspection:

1. Does the inspection frequency meet the required 15 month but at least once each calendar year criteria?

2. Is there sufficient information to identifj make, type, size, and location of relief valve?

3.

4.

Are the found and left set pressures indicated and within the MAOP?

Is there any indication that the valve isnat in good mechanical condition?

5. Is there any indication that the valve is not protected h m conditions (dirt, liquids, etc.) that might prevent proper operation?

A) Missingraincap

B) Plugged drainhole?

C) Leaking or corroded control lines, etc.?

B. Mainline Regulators - (Presswe Limiting Valves)

1. The inspection fkquency does not exceed 15 months and is within the calendar Year?

2. Is there sufficient information to identify make, type, size and location of regulator and controller?

3. ' Pressures settings are recorded and are within the respective MAOP's?

4. The capacity is calculated, and the volume is sufficient to protect the MAOP?

Tab 2-B -Line Specific Files Revised: 2/4/99

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t LINE SPECIFIC FnES PIPELINE Quality Assurance Auditing Procedure

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5. The regulator and controller are checked for leakage or other conditions which may impair their operation?

C. Ifthere are no overpressure protection devices on the pipeline,

1. Is protection provided by plants or stations?

2. How is the pipeline MAOP protected?

VALVES: Valves, Valve Operators and Blowoffs (192.745 - O&M Sa. 201.4)

A. Valve Identification

1. Are all mainline valves and valve operators, if equipped, identified?

2. Is there sufficient information to identify make, type, size, pressure rating and location (or service) of each valve?

3. Is the pressure rating of the valves commensurate with the pipeline MAOP?

B. Valve Inspection

1. Are all valves and operators inspected at intervals not exceeding 15 months but at least once each calendar year?

2. Are all valves inspected for leakage?

3. Are all valves and operators inspected for potentially detrimental conditions, such as:

A) Rust or corrosion?

B) Stability and support of valve?

C) Flange bolts tight?

D) Valve box and/or valve is readily accessible?

E) Protection against tampering (locked, etc.) if near a public area or public road?

C. Valve Operation & Lubrication

1. Are valves and operators at least partially operated at intervals not exceeding 15 months but at least once each calendar year?

Tab 2-B - Line Specific Files Revised: 2/4/99

PIPELINE Quality Assurance Auditing Procedure -i LliW SPECIFIC FILES Page 3

2. As needed, are valves and operators lubricated to assure ease in operation and to prevent or stop leaking?

D. RemarksSection

1. Is there space on the maintenance and inspection form for remarks as to any detrimental conditions?

2. If so, are any conditions noted?

3. If conditions are noted, are remedial or corrective actions indicated?

4. Is it apparent that the Complex Manager is aware of the condition by

A) Initialdsignature?

B) Documented follow-up a G t i ~ n ~ taken?

Patrolling: (Also visual leakage survey) (192.705 - O&M Sec. 202.3,202.4,505,506 and 507)

A. What are the class locations on the pipeline, and are patrols in

1. Class 1 & 2, at intervals not exceeding 7 1/2 months but at least twice each calendar year at Highway and Railroad Crossings, and 15 months but at least once each calendar year along the rest of the line?

2. Class 3, 4 1/2 months but at least four times a calendar year at Highway and Railroad crossings and 7 1/2 months but a least twice a year at all other places?

3. Class 4,4 1/2 months but at least four times a calendar year at all locations?

B. Does the report indicate the observation of Right-of-way conditions, such as

1. Leaks or possible leaks?

A) Dead or dying vegetation?

B) Change in soil color, etc.?

2. Encroachments or potential encroachmenb?

3. Construction activity in the areas?

4. Water flow and drainage diversions needed or in need of repair? Tab 2-B - Line Specific Files Revised: U4B9

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PIPELINE Quality Assurance Auditing Procedure 2- LINE SPECIFIC FILES

5. Exposed pipe?

6. Anyother?

C. Isthereport

1. Signed by the observer?

2. Initialed by the Complex Manager or Lead?

Page 4

D. Do conditions, such as those in B above, have responses to indicate

1. Further investigation has been made?

2. Corrective action or remedial measures have been taken?

3. Comtive action or remedial measures have been scheduled within a practical time Erame3

Leaks, Damage and Failures: (192.71 1,713, 717, 719,241,475 - O&M Sec201.2,201.3,504, and 607)

A. Are leak, damage and failure reports prepared?

B. Are notifications made in accordance with Sec. 504 of the O&M Manual?

C. Was the repair temporary or permanent?

D. If tempomy repair,

1. What was the method of repair?

2. And if a boltsn leak clamp was used, was

A) The leak due to a u u m s h p t ' ?

B) when making apemanat repair?

The location marked and recorded to assist in rechecking or

E. Ifpermanent repair,

1. And a welded patch was used, was the leak a corrosion pit and on pipe of not more than 40,000 S M Y S ?

Tab 2 8 - Line Specific Files Revised: 2/4/99

H. PIPELINE Quality Assurance Auditing Procedure

P LIhE SPECIFIC FEES Page 5

2. And the pipe was replaced,

A) Was the pipe of adequate design and hydrostatically tested?

B) Were the welds x-rayed? or,

C) Were the welds visually inspected by welding inspector on

1) Pipe less than 6" in diameter? or,

2) Pipeline operates at less than 40% of S M Y S ? and,

3) The welds are so limited that testing is impractical?

F. Ifthe pipeline was not repaired, and the line was shut-in or the line pressure lowered,

1. Was the condition not reportable as an incident ( O M Sec. 504)? and,

2. Was the condition safety related? and,

3. Did the condition meet the reporting criteria of a "Safety Related Condition" (O&M, Sec. 400)?

G. When the pipe was uncovered,

1. Was an inspection of the pipe and coating made by a technician verified to that bellhole level? and,

2. Was it recorded on a pipe inspection or bell-hole report?

H. Ifthe pipe was replaced, was the intemal surface inspected for corrosion? and, 1. If no corrosion found, was that noted on the pipe inspection fom?

2. If corrosion was found, were the following steps taken?

A)

B)

C)

Was adjacent pipe checked for internal corrosion?

Did the replacement include the adjacent pipe, if necessary?

Were steps taken to minimize the i n t d corrosion? if so, what steps?

Measurement: Relief Valves and Regulators (192739,745 - O&M Sec. 202.8)

A. Do inspections and tests meet the 15-monWcalendar year fkquency requirement?

Tab 2-B - Line Specific Files Revised: 2/4/99

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PIPELINE Quality Assurance Auditing Procedure t- LLNE spEcIFIc FILES Page 6

B. Have all meter stations on the pipeline been identified?

C. Is a form 11-0191 filled out and signed for each station?

D. Are capacity calculations entered on the form?

E. Are station valves inspected, greased and ?

F. Are rain caps checked?

G. Are R V. drainholes checked?

H. Are any repairs, adjustments, etc. indicated in the remarks section?

I. Are any problems detrimental to the station operation recorded? If so, are corrective actions "mended or taken?

C Q " 2 I I - See Survey Codes and Limits Sheets (1 92.45 1 through 491 - O&M Sec. 201.2 and 201.3)

A. Annualsurvey

1. Are surveys conducted within &month intervals but at least once each calendar year?

2. Are items which would require investigation or remedial action identified on the survey, such as

A) Missing test point readings?

B)

C) Interference suspected?

D)

E)

F)

G) Etc.?

For items requiring remedial measures or indicating trends in that direction,

P/S reading below 850 mV?

A short detected in road casing?

Atmospheric coating/corrosion (3.3 or less)?

P/S reading above 2500 mV?

3.

A) Are remedial action foms initiated? Tab 243 - Line Specific Files Revised: 2/4/99

PIPELINE Quality Assurance Auditing Procedure r LINE SPECZFIC FZLES Page 7

B) Is the documentation brought to the attention of responsible supervision?

C) Will the items be corrected within a prompt but reasonable time fi-ame?

B. Bell-Hole Inspections

1. Pipe Inspection Data (Form 7-242) was filled out and signed by employee verified to that bellhole level?

2.

3.

Were all pertinent items addressed?

Ifwarranted, was a Remedial Action form initiated?

C. Shorted Casings

1. Were steps taken to clear the short? or,

2. Was the casinglpipe annulus filled to inhibit corrosion? or,

3. Is the casing being monitored with leak detecting equipment every six months in Class 1 and 2; and, every three months in Class 3 or 4?

Tab 2-B - Line Specific Files Revised: 2 I 4 M