Project Spotlight: Facility IMP

Elemental Compliance developed gas and liquid Facility Integrity Management Programs for an operator with over 20 jurisdictional facilities. Recently the gas program was audited by PHMSA and received no findings.

This project came in response to PHMSA’s increased inspection focus on integrity management for facilities. This portion of the code has always existed but PHMSA has increased the depth and breadth of their inspections when it comes to going “inside the fence”. Employing over 25 years of experience combined with insight gained through the API 2611 workgroup (which is currently in the process of developing a standard for facility risk for liquid operators), Elemental SMEs worked with the client to develop Facility IMP procedures and forms, a Facility risk algorithm, and to assist with implementation of the program.

As Facility IMP is a fairly new area of inspection focus, Elemental Compliance developed solutions and processes for facilities where needs differed from pipeline IMP. Some examples are developing a repeatable process for determining which assets were HCA facilities, creating a risk algorithm that identifies threats and consequences on an asset-specific and facility-wide level, identifying facility-specific preventive and mitigative measures, and outlining metrics to track the progress of the program over time. All of these areas presented differences and deviations from the corresponding methods that are so well established for pipelines. The successful audit of the gas portion of the client’s Facility IMP shows that, though this is a new audit arena, Elemental Compliance’s expertise and experience can successfully guide you through this process, regardless of asset size, commodity type, or facility complexity. If you find yourself needing support in this area call on Elemental Compliance experts today!