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PHMSA Established an Effective Integrated Inspection Program but Needs To Strengthen Guidelines To Mitigate Risks

Self-Initiated
Project ID: 
ST2023032
What We Looked At
As part of its oversight responsibilities, the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Office of Pipeline Safety (OPS) conducts pipeline inspections, including integrated inspections that combine elements of various safety inspections. We conducted this audit because integrated inspections make up the majority of OPS’ inspections and can identify possible impacts on pipeline safety. Our audit objective was to assess PHMSA’s implementation of integrated inspections, specifically to assess the Agency’s policies and procedures, risk-based approach, and conduct of integrated inspections.
 
What We Found
PHMSA has established procedures and information systems to plan and conduct integrated inspections and document results. The integrated inspections we reviewed followed these procedures, were prioritized by risk, and resolved unsatisfactory conditions. In developing PHMSA’s annual inspection plans, PHMSA’s Risk Ranking Index Model (RRIM) uses risk factors to code high, medium, and low scores for when pipeline systems should be inspected. OPS also verifies that, to the extent possible, no system goes without inspection for more than 7 years and unsatisfactory conditions found in inspections are addressed. Nevertheless, PHMSA’s guidelines for integrated inspections have control weaknesses. Specifically, while the manual covers most of the integrated inspection process, some sections are out of date and others do not reflect actual practices. Furthermore, 7 of 18 inspections we analyzed had missing or draft system profiles even though these profiles are integral to the inspection planning process. Finally, the risk factors that RRIM uses to calculate pipeline system risk scores inadequately considered several statutorily required factors for PHMSA’s decisions on how frequently to inspect pipeline systems.
 
Recommendations
We made three recommendations to help PHMSA improve its integrated inspection program and the Agency concurs with all three recommendations.

Recommendations

Open

Closed

No. 1 to PHMSA

Update the Integrated Inspection User’s Manual to reflect current processes and systems used and clarify requirements for system profiles.

No. 2 to PHMSA

Develop and implement a plan for ensuring supervisors verify lead inspectors have completed all documentation requirements identified in the Integrated Inspection User’s Manual.

No. 3 to PHMSA

Update RRIM Documentation with an explanation for how pipeline age and manufacturer, volume transported, pressure, seismicity, climate, geology, and demography should or should not be considered as part of the Risk Ranking Index Model.