Integrity Management Program

April 11, 2018 – In Pennsylvania the Public Utility Commission is the state agency that has the responsibility for implementing the Federal pipeline safety regulations. These regulations require that a pipeline company like Sunoco develop and implement an Integrity Management Program (IMP).

According to information posted on the Pipeline and Hazardous Material Safety Administration website an IMP is “a set of safety management, operations, maintenance, evaluation, and assessment processes that are implemented in an integrated and rigorous manner to ensure operators provide enhanced protection for HCAs.”

I recently contacted the Public Utility Commission about the process for reviewing an IMP and their response is as follows:

“My engineers review the IMP.  We send a team of engineers into Sunoco’s office and review the IMP for compliance to the Federal Pipeline Safety Code.  The inspection takes approximately 10 days in their office and then another five to seven days for us to review the data internally and submit the final inspection.  We analyze the calculations and assessments and review their risk data.  We do not approve an IMP but we review it for compliance.  Additionally, the federal inspectors also perform an IMP review.  Usually the PUC and PHMSA do not perform the IMP together, but as a separate agency review.  So there are two groups of eyes and different times reviewing it for compliance.  Also, as we perform other inspections during the year we often open the IMP and make sure it’s being changed/reviewed by Sunoco.  The IMP is a living breathing document. “