Integrity Management Program Special Permits (IMP-SP) Draft Administrative Plan 12/5/2007

IMP Special Permit Criteria Process Criteria –The operator must have an acceptable IM program Personnel Criteria –The operator personnel administering and performing the IM program must be qualified Technical Criteria –The pipeline segments must satisfy the technical criteria during the baseline inspection period and subsequent reassessment periods

Information needed by PHMSA to Satisfy IMP-SP IMP-SP Plan, Process and Criteria (Joint) Results of PHMSA audited company program –Process Audit (PHMSA) –Personnel Audit (PHMSA) Proposed Plan for IMP Segments to be included –Technical proposal (Operator) –Reporting proposal (Operator)

IMP-SP Permit Process Timeline Applicant notifies PHMSA of intent to enter program (Letter of Intent) The timeline for the initial submission, processing and approval of a Letter of Intent and subsequent information is as follows: –During the month of February, the operator will submit their Letter of Intent (Operator, PHMSA ID, Contact information) –During the month of March and within 30 days of a company’s submission of a company’s Letter of Intent, PHMSA will review the Letter of Intent and notify the operator of tentative approval or rejection –During the period of March 11 through March 31 the company will submit information concerning specific segments for which they intend to include and retain in the special permit for the upcoming year (IMP- SP Application) –During the period of March 11 through June 30 and within 90 days of a companies submission of specific segments, PHMSA will review the specific segment information and notify the operator of approval or rejection This timeline will allow operators to have approval or rejection prior to the budget process which typically begins in July for the following year’s projects

Initial IMP-SP Application (filed after pipeline company receives approval to enter the IMP-SP program from PHMSA based on submittal of Letter of Intent) Operator Name and Address PHMSA User ID Contact information Description of Segment(s) Date of last integrity assessment(s) by segment Date of next integrity assessment(s) by segment Justification Statement to enter IMP-SP Program signed by operating company officer

Applicant IMP-SP Process Criteria Operator must have an implemented Integrity Management Program Operator must have an implemented Operations and Maintenance program Operator must have an implemented Drug and Alcohol program Operator must have an implemented Public Awareness Program Operator records must demonstrate appropriate management of the pipeline system

PHMSA Criteria For IMP-SP (Process Acceptance) At least one PHMSA Audit conducted concerning their IMP program –The IMP Audit must be complete and all identified issues communicated to the operator –Unresolved NOPVs as result of the completed IMP audit must be documented by PHMSA and Applicant; good faith effort for addressing unresolved NOPVs will be considered –Unresolved NOAs as a result of the completed IMP audit must be documented by PHMSA and Applicant; good faith effort for addressing unresolved NOAs will be considered PHMSA accepts or denies applicant’s process performance as result of completed IMP audit(s)

Applicant Personnel Criteria Operator must have personnel that are qualified per company’s Operator Qualification Plan and Drug and Alcohol program Operator must have a management structure which supports operations, maintenance and integrity management with demonstrated commitment to pipeline safety Operator must have a technical staff or access to experts to determine the technical aspects of the integrity management program and the special permit

PHMSA Criteria for IMP-SP (Personnel Acceptance) At Least One PHMSA Audit Conducted concerning their Operation and Maintenance (O&M), Operator Qualification (OQ) and Drug and Alcohol (D&A) Plan program –The PHMSA I&M and OQ Audit must be complete and all identified issues communicated to the operator. Operator must certify they have a D&A Plan in conformance with Parts 199 and 40. –Unresolved NOPVs as result of the completed audits must be documented by PHMSA and Applicant; good faith effort for addressing unresolved NOPVs will be considered –Unresolved NOAs as a result of completed audits must be documented by PHMSA and Applicant; good faith effort for addressing unresolved NOAs will be considered PHMSA accepts or denies applicant’s process performance as result of these filed audits

Applicant IMP-SP (Technical Criteria) Inline Inspection (ILI) or pressure test (PT) must have been conducted as the IMP assessment technique on a segment at least one time Predicted pipeline corrosion rates for a segment must be forecasted and deemed appropriate for proposed extended interval Post IMP assessment repairs must be documented and analysis performed to determining segment is in satisfactory condition Segment must not have experienced an incident or leak caused by corrosion; subsequent to an IMP assessment of segment Pipeline Segments with special conditions (e.g. MIC, SSC, SCC, or non-tariff spec gas) require specific analysis to address the special conditions

PHMSA Criteria for IMP-SP (Technical Acceptance) Documentation provided by applicant should describe the segment and clarify if the segment meets the following criteria –No bare steel pipe –No pipe with ineffective coating systems –No pipe with ineffective cathodic protection –No pipe that was assessed by other than ILI or hydrostatic pressure test for the IMP program –For pipe with known history of MIC, SSC, or SCC, the IMP must contain provisions for addressing and managing the threat –For pipe never hydrostatically pressure tested plan must justify why lack of pressure test does contribute to corrosion threat PHMSA accepts or denies applicant’s process performance as result of filed technical information

Yearly Report & Application for Additional Segments by IMP-SP Participants Companies will submit an annual report during March of each year. The annual report will include the following: –Confirmation of the company’s Initial IMP-SP Application information –Status of the segments previously approved as part of the IMP-SP –Addition or deletion of any segments to the special permit –Status on the completion of scheduled or unscheduled repairs on the segments