0
Not in place
No documented process, no assigned owner, or no evidence that the control exists.
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$49 Pipeline Compliance Readiness Self-Assessment
Printable readiness workbook for pipeline safety and methane compliance.
This assessment is designed for small and mid-size natural gas operators that need a practical way to score current-state readiness across PHMSA, EPA, California CPUC, and CARB obligations.
Scored Controls
57
Maximum Score
171
Included
- Introduction, scoring guide, and section-by-section review prompts.
- 57 scored questions across federal and California compliance topics.
- Color-band rubric, gap analysis template, and a 90-day action plan framework.
- Print-friendly formatting so the page can be saved directly as a PDF deliverable.
Best Use
Complete this workbook with operations, integrity, environmental, and compliance owners in the same session. Use documents and actual records as your source of truth. When in doubt, score the lower number and capture the gap.
Suggested reviewers
Operations manager, integrity lead, environmental compliance owner, California program lead, and the person responsible for document control or audit response.
Introduction
How to use this assessment
- 1. Review one section at a time and score each item from 0 to 3 based on current evidence.
- 2. Write comments beside any item that depends on tribal knowledge, outdated records, or a contractor-controlled process.
- 3. Total each section, compare it to the rubric, and flag the controls that create the biggest inspection or methane-risk exposure.
- 4. Use the gap analysis and 90-day template at the end to turn low scores into sequenced actions with owners and dates.
Scoring reminder
Score the control, not the effort. A process that exists but cannot be evidenced during an audit should not score above a 1. A process that is documented but routinely overdue usually lands at a 2 until the closure discipline improves.
0-3 Scoring Guide
1
Partial / reactive
The control exists in pockets, but it is inconsistent, informal, or not supported by records.
2
Defined / repeatable
The process is documented and generally followed, but monitoring or closure discipline is uneven.
3
Implemented / evidenced
The control is documented, consistently executed, periodically reviewed, and easy to prove in an audit.
Section 1: PHMSA Pipeline Safety
20 questions on integrity management, O&M procedures, OQ, and leak response
Use this section to evaluate whether your pipeline safety program is documented, current, and field-proven. Score based on evidence, not intent.
Questions
20
Max score
60
Focus areas
- Integrity Management Program governance and HCA segmentation
- Assessment planning, anomaly response, and repair closure
- Operations and maintenance procedures with field accessibility
- Operator qualification, contractor oversight, and leak response execution
Documents to review
- IMP plan, threat/risk model, and recent integrity assessment packages
- O&M manual, abnormal operating condition procedures, and emergency plans
- Operator qualification records, contractor oversight files, and leak survey logs
PHMSA-01
IMP scope and segmentation
0
1
2
3
Are covered segments, high consequence areas, and class-location assumptions mapped and reviewed on a defined annual cadence?
Evidence to review: Current GIS or mapping output, HCA review memo, class-location change log, and annual management review notes.
PHMSA-02
Threat identification discipline
0
1
2
3
Does the integrity management program explicitly evaluate time-dependent, stable, and time-independent threats for each applicable segment?
Evidence to review: Threat matrix, segment risk files, corrosion and geohazard studies, and incident trend reviews.
PHMSA-03
Risk model quality
0
1
2
3
Is your risk-ranking methodology current, documented, and supported by validated inputs such as material, vintage, pressure, leak history, and consequence data?
Evidence to review: Risk model procedure, data dictionary, validation checks, and recent risk-ranked segment list.
PHMSA-04
Assessment planning
0
1
2
3
Have all required baseline and reassessment activities been completed on time or formally deferred with technical justification?
Evidence to review: Assessment schedule, reassessment calendar, engineering justifications, and management approvals.
PHMSA-05
Assessment method selection
0
1
2
3
Do you document why each segment uses inline inspection, pressure test, direct assessment, or another accepted method?
Evidence to review: Method-selection criteria, engineering evaluations, and segment-specific assessment workpapers.
PHMSA-06
ILI and assessment review
0
1
2
3
Are inline inspection, hydrotest, or direct assessment results reviewed by qualified personnel against defined acceptance criteria?
Evidence to review: ILI vendor reports, engineering disposition records, hydrotest summaries, and reviewer signoffs.
PHMSA-07
Anomaly response criteria
0
1
2
3
Do you maintain clear criteria for immediate, 60-day, and 180-day conditions and apply them consistently across anomaly reviews?
Evidence to review: Repair criteria procedure, anomaly log, and sample repair classifications from recent inspections.
PHMSA-08
Repair closure control
0
1
2
3
Are repairs tracked from discovery through excavation, engineering disposition, completion, and record retention without open-ended gaps?
Evidence to review: Repair tracker, excavation reports, closeout packages, and overdue item escalation records.
PHMSA-09
MAOP traceability
0
1
2
3
Can you readily produce traceable records supporting MAOP, pressure test history, class location, and material verification for affected assets?
Evidence to review: MAOP validation files, traceable records index, pressure test records, and material verification documentation.
PHMSA-10
Change management
0
1
2
3
Do pipeline replacements, uprates, tie-ins, and class changes trigger a formal review of procedures, risk data, and integrity obligations?
Evidence to review: Management-of-change workflow, engineering review checklist, and completed MOC packages.
PHMSA-11
O&M procedure currency
0
1
2
3
Are operations and maintenance procedures current, version-controlled, and accessible to field teams performing the work?
Evidence to review: Controlled procedure list, revision approvals, distribution record, and field access screenshots or binders.
PHMSA-12
Abnormal operations and emergency response
0
1
2
3
Do abnormal operating condition and emergency procedures define thresholds, notifications, and field actions clearly enough to support rapid execution?
Evidence to review: Emergency plan, AOC procedure, drill evaluations, and after-action reports.
PHMSA-13
Leak detection roles
0
1
2
3
Are controller, dispatch, field, and supervisor responsibilities for leak recognition, alarm response, and escalation documented and practiced?
Evidence to review: Alarm response matrix, control room procedures, leak callout workflow, and drill attendance records.
PHMSA-14
Preventive inspection scheduling
0
1
2
3
Are valves, regulators, overpressure protection, rectifiers, and other critical assets inspected on schedule with complete records?
Evidence to review: Maintenance schedule, completed inspection forms, exception log, and overdue asset list.
PHMSA-15
Leak survey performance
0
1
2
3
Do patrols and leak surveys occur at the required frequency for each asset class, and are missed intervals formally escalated?
Evidence to review: Leak survey calendar, patrol records, missed-inspection tracker, and supervisory review notes.
PHMSA-16
Operator qualification scope
0
1
2
3
Is there a current covered-task inventory that aligns with actual field work performed by employees and contractors?
Evidence to review: Covered task list, task-to-role matrix, and recent field audit comparisons.
PHMSA-17
Operator qualification status
0
1
2
3
Are OQ evaluations current, evidence-based, and easy to verify before work is assigned?
Evidence to review: Evaluation records, qualification expirations dashboard, and pre-job verification process.
PHMSA-18
Contractor oversight
0
1
2
3
Do you verify contractor qualifications, procedure adherence, and stop-work authority rather than relying only on contract language?
Evidence to review: Contractor oversight checklist, field audit reports, kickoff materials, and corrective action records.
PHMSA-19
Incident and near-miss learning
0
1
2
3
Are incidents, near misses, and excavation damages reviewed for root cause and translated into procedure, training, or design updates?
Evidence to review: Root-cause analyses, lessons-learned bulletins, and resulting procedure or training revisions.
PHMSA-20
Leadership review and accountability
0
1
2
3
Does management review pipeline safety metrics, overdue actions, and repeat findings often enough to prevent issues from lingering?
Evidence to review: Quarterly review deck, KPI dashboard, overdue-action log, and assigned leadership owners.
Section 2: EPA Methane Emissions
15 questions on Subpart W, surveys, pneumatics, and fugitive emissions controls
Use this section to determine whether methane obligations are supported by a complete asset inventory, repeatable monitoring, and defensible annual reporting.
Questions
15
Max score
45
Focus areas
- Subpart W applicability, activity data, and annual report QA
- Fugitive emissions surveys, repair closure, and survey method control
- Pneumatic devices, venting minimization, and control-device oversight
- Record retention and management review before EPA submission
Documents to review
- Subpart W inventory, emissions calculation workbooks, and annual reports
- LDAR procedures, survey schedules, repair tracker, and technician qualifications
- Pneumatic device inventory, maintenance venting logs, and record retention index
EPA-01
Applicability mapping
0
1
2
3
Have you mapped all applicable assets and operations to the correct EPA greenhouse gas and methane reporting source categories?
Evidence to review: Applicability memo, asset inventory, facility list, and source-category mapping workbook.
EPA-02
Emission calculation methodology
0
1
2
3
Is the calculation method for each reportable emission source documented, approved, and consistent year over year unless formally changed?
Evidence to review: Calculation methodology file, revision history, and reviewer approval records.
EPA-03
Activity data completeness
0
1
2
3
Do meter readings, run times, counts, and equipment attributes feeding the annual report reconcile to source systems without unexplained gaps?
Evidence to review: Activity data extracts, reconciliations, missing-data log, and QA signoff.
EPA-04
Annual reporting calendar
0
1
2
3
Is there a formal reporting calendar with assigned owners, internal due dates, and review checkpoints ahead of submission deadlines?
Evidence to review: Compliance calendar, RACI chart, submission checklist, and review meeting cadence.
EPA-05
Measurement and calibration control
0
1
2
3
Are instruments and measurements used in methane reporting calibrated, maintained, and traceable to the records retained for the reporting year?
Evidence to review: Calibration logs, maintenance certificates, and instrument inventory.
EPA-06
Leak survey coverage
0
1
2
3
Do leak surveys cover the right assets at the right interval for your EPA-obligated methane program, including hard-to-access equipment?
Evidence to review: Survey route list, coverage map, skipped-component log, and completion metrics.
EPA-07
Survey method discipline
0
1
2
3
Are OGI, Method 21, or other approved survey methods governed by written procedures and technician competency requirements?
Evidence to review: Survey procedure, training records, OGI certification files, and field QA checklists.
EPA-08
Repair closure performance
0
1
2
3
Are identified leaks prioritized, repaired, rechecked, and documented within the required or internally committed timeframes?
Evidence to review: Leak repair tracker, repair confirmations, delayed-repair approvals, and re-monitoring records.
EPA-09
Fugitive emissions program ownership
0
1
2
3
Does the fugitive emissions program assign clear ownership for surveys, repairs, data entry, QA, and escalation of overdue items?
Evidence to review: Program charter, responsibility matrix, and escalation workflow.
EPA-10
Pneumatic device inventory
0
1
2
3
Is there a current inventory of pneumatic devices showing bleed rate, service, location, and replacement status where restrictions apply?
Evidence to review: Pneumatic inventory, device specifications, field verification results, and change logs.
EPA-11
Pneumatic reduction strategy
0
1
2
3
Have you identified high-bleed or high-emitting pneumatics and established a practical replacement or retrofit plan?
Evidence to review: Retrofit project list, capital plan inputs, engineering evaluations, and completion status.
EPA-12
Venting minimization
0
1
2
3
Are planned blowdowns, maintenance venting, and compressor depressurization events minimized, approved, and logged with enough detail to support reporting and follow-up?
Evidence to review: Venting log, work permits, event approvals, and post-event review notes.
EPA-13
Control device oversight
0
1
2
3
Where tanks or other systems rely on control devices, do you monitor uptime, malfunctions, and corrective actions in a documented way?
Evidence to review: Control-device inspection logs, malfunction reports, and maintenance work orders.
EPA-14
Management review before submission
0
1
2
3
Does leadership or a designated reviewer challenge assumptions, large year-over-year swings, and unusual estimates before EPA filing?
Evidence to review: Management review checklist, variance analysis, and approval record before submission.
EPA-15
Retention and retrieval
0
1
2
3
Can you quickly assemble the records supporting your methane program and annual report if EPA or a state partner requests them?
Evidence to review: Retention schedule, shared-file index, sample audit package, and retrieval-time test.
Section 3: California CPUC
12 questions on GO 112-F, GS standards, DIMP, and recordkeeping
Use this section if you operate California gas assets or support an intrastate operator. The goal is to test whether state-specific requirements are translated into field-ready controls and audit-ready records.
Questions
12
Max score
36
Focus areas
- GO 112-F and California gas safety requirements embedded in procedures
- Distribution integrity management, leak metrics, and leadership review
- Emergency response, corrosion control, and construction record discipline
- CPUC audit response, corrective actions, and documentation retrieval
Documents to review
- California compliance matrix, GO 112-F procedure crosswalk, and DIMP plan
- Leak survey records, corrosion control files, and emergency liaison documentation
- CPUC audit reports, corrective action tracker, and record retention index
CPUC-01
GO 112-F crosswalk
0
1
2
3
Have applicable GO 112-F requirements been translated into a maintained compliance matrix and linked to operational procedures?
Evidence to review: California compliance matrix, procedure crosswalk, and owner assignment log.
CPUC-02
State responsibility assignment
0
1
2
3
Are CPUC-specific safety responsibilities assigned by function so field, engineering, and compliance teams know who owns what?
Evidence to review: RACI chart, role descriptions, and California-specific governance notes.
CPUC-03
DIMP currency
0
1
2
3
Is the distribution integrity management plan updated with current leak history, excavation damages, material risks, and preventive actions?
Evidence to review: Current DIMP plan, risk updates, leak trend analysis, and revision approvals.
CPUC-04
DIMP performance measures
0
1
2
3
Do you review performance measures and threat trends often enough to adjust priorities before CPUC findings accumulate?
Evidence to review: Metric dashboard, management review minutes, and documented action items.
CPUC-05
Inspection interval compliance
0
1
2
3
Are leak surveys, patrols, regulator inspections, and valve checks completed within California-required intervals and easy to prove?
Evidence to review: Inspection schedule, completion reports, exceptions list, and supervisory review.
CPUC-06
Emergency and liaison readiness
0
1
2
3
Are emergency plans, fire and local agency liaison activities, and public awareness obligations current and documented?
Evidence to review: Emergency plan, liaison meeting notes, public awareness materials, and drill records.
CPUC-07
Construction and test records
0
1
2
3
Can you produce complete records for installations, inspections, pressure tests, and material specifications for recent California work?
Evidence to review: As-built records, pressure test packages, inspection reports, and material certifications.
CPUC-08
Corrosion control documentation
0
1
2
3
Are rectifier readings, cathodic protection surveys, isolated short investigations, and remedial actions current and complete?
Evidence to review: CP survey logs, rectifier records, exception resolutions, and corrosion action tracker.
CPUC-09
Training and field verification
0
1
2
3
Do California personnel and contractors receive state-specific training, and do you verify execution through field audits rather than classroom completion alone?
Evidence to review: Training matrix, attendance logs, field audit forms, and corrective action records.
CPUC-10
Record retrieval speed
0
1
2
3
Can the organization assemble requested CPUC records within a short timeframe without relying on tribal knowledge?
Evidence to review: Document index, mock audit retrieval test, and standardized folder structure.
CPUC-11
Corrective action closure
0
1
2
3
Are findings from CPUC audits, investigations, and internal reviews assigned, prioritized, and tracked to verified closure?
Evidence to review: Corrective action log, aging dashboard, owner assignments, and closure validation.
CPUC-12
Leadership visibility
0
1
2
3
Does management receive a concise view of California compliance metrics, overdue actions, and repeat findings that drives real decisions?
Evidence to review: Leadership dashboard, escalation criteria, and recurring governance meeting materials.
Section 4: CARB Air Quality
10 questions on methane controls, California air obligations, and LDAR discipline
Use this section to assess whether California methane and air-quality obligations are embedded in operations, recordkeeping, and executive oversight rather than handled as one-off reporting exercises.
Questions
10
Max score
30
Focus areas
- CARB applicability, methane reduction obligations, and facility coverage
- Leak detection and repair discipline for California assets
- Pneumatic, venting, and emissions data governance in-state
- Alignment across CARB, CPUC, EPA, and internal reporting channels
Documents to review
- CARB applicability analysis, methane survey procedures, and emissions logs
- Repair tracker, pneumatic replacement plan, and venting or flaring records
- California reporting package, management dashboard, and training records
CARB-01
Applicability determination
0
1
2
3
Have you identified which California assets, facilities, or operating activities are subject to CARB methane or air-quality obligations?
Evidence to review: Applicability memo, facility inventory, and California asset coverage map.
CARB-02
California program translation
0
1
2
3
Are CARB methane rules and California decarbonization commitments such as AB 1322 or SB 1440 translated into an operational checklist for affected teams?
Evidence to review: California obligations register, role-based checklist, and procedure references.
CARB-03
LDAR procedure quality
0
1
2
3
Do California leak-detection procedures define asset coverage, survey frequency, approved methods, and documentation expectations clearly enough for field use?
Evidence to review: California LDAR procedure, route list, survey intervals, and field forms.
CARB-04
Repair prioritization
0
1
2
3
Are leaks triaged and repaired according to a documented priority system with escalation for overdue or repeat leaks?
Evidence to review: Repair priority criteria, open leak list, overdue report, and re-inspection records.
CARB-05
Venting and flaring event control
0
1
2
3
Are venting or flaring events approved, logged, and analyzed for preventable root causes and methane-reduction opportunities?
Evidence to review: Event log, cause coding, approval record, and follow-up action tracker.
CARB-06
Pneumatic replacement progress
0
1
2
3
Do you track low-bleed or no-bleed pneumatic conversions for California-covered assets with enough visibility to manage schedule risk?
Evidence to review: Replacement project tracker, asset inventory, and capital planning notes.
CARB-07
Cross-agency data consistency
0
1
2
3
Are methane figures, asset counts, and repair metrics reconciled across CARB, CPUC, EPA, and internal operations reports?
Evidence to review: Cross-agency reconciliation workbook, data quality review, and discrepancy log.
CARB-08
California-specific training
0
1
2
3
Have operations, maintenance, and contractor teams been trained on California-specific methane and air obligations that differ from federal expectations?
Evidence to review: Training material, completion records, and field interview or audit results.
CARB-09
Recordkeeping package
0
1
2
3
Can you produce survey logs, repair evidence, calibration records, exemptions, and emissions summaries for California regulators on demand?
Evidence to review: Records index, sample CARB response package, and retention schedule.
CARB-10
Executive oversight
0
1
2
3
Does leadership receive visibility into methane reduction progress, overdue repairs, and enforcement exposure for California assets?
Evidence to review: Executive dashboard, board or leadership updates, and exception escalation criteria.
Scoring Rubric
Interpret scores by section first, then overall.
A high overall score can hide a major weakness in a single program area, so do both calculations. Red sections deserve immediate attention even if the total score lands in Yellow.
Overall maximum score: 171
| Area | Max | Green | Yellow | Red |
|---|---|---|---|---|
| 1: PHMSA Pipeline Safety | 60 | 51 - 60 | 36 - 50 | 0 - 35 |
| 2: EPA Methane Emissions | 45 | 39 - 45 | 27 - 38 | 0 - 26 |
| 3: California CPUC | 36 | 31 - 36 | 22 - 30 | 0 - 21 |
| 4: CARB Air Quality | 30 | 26 - 30 | 18 - 25 | 0 - 17 |
| Overall score | 171 | 146 - 171 | 103 - 145 | 0 - 102 |
Green
146 - 171Controls are largely in place. Focus on documentation quality, aging exceptions, and management review discipline.
Yellow
103 - 145Core controls exist, but inconsistency or incomplete evidence increases inspection and enforcement risk.
Red
0 - 102Material gaps are likely. Prioritize overdue controls, record retrieval, and ownership before expanding the program.
Gap Analysis Framework
Convert weak scores into specific, owned findings.
Start with every question scored 0 or 1, then add any 2-rated controls that have overdue actions or weak evidence. The goal is to build a short list of high-value fixes, not to create a giant issue register.
| Finding | Section | Priority | Recommended action | Owner / due date |
|---|---|---|---|---|
Priority 1
Missing legally required controls, overdue repairs, missing records, or findings that could drive enforcement or unsafe operation.
Priority 2
Controls exist but are inconsistent, manual, or vulnerable to repeat misses during inspection, reporting, or turnover.
Priority 3
Improvement work that strengthens resilience, reporting speed, or audit readiness after major gaps are already contained.
90-Day Action Plan Template
Prioritize next steps based on the score band you earned.
The right 90-day plan depends on score quality. Red organizations need a stabilization sprint. Yellow organizations need closure discipline and evidence quality. Green organizations need tighter governance so performance stays durable.
If overall score is Red
- Stand up a weekly remediation meeting with executive visibility.
- Fix overdue inspections, missing records, and open leak or repair issues first.
- Freeze low-value projects until core compliance obligations are stabilized.
If overall score is Yellow
- Standardize evidence packages, dashboards, and owner accountability.
- Clear repeat exceptions and any controls that routinely score 1 in audits.
- Use quarterly reviews to prevent drift back into reactive compliance.
If overall score is Green
- Focus on automation, management review, and cross-agency data consistency.
- Audit sample records proactively so readiness stays provable.
- Use the next 90 days to strengthen resilience, not just maintain status quo.
| Time window | Top objective | Priority actions | Owner | Due date / status |
|---|---|---|---|---|
| Days 0 - 30 | ||||
| Days 0 - 30 | ||||
| Days 31 - 60 | ||||
| Days 31 - 60 | ||||
| Days 61 - 90 | ||||
| Days 61 - 90 |
Recommended cadence: review the action plan weekly for Red scores, biweekly for Yellow scores, and monthly for Green scores. Re-run the self-assessment after major procedure updates, before annual reporting deadlines, or ahead of a known inspection cycle.
Final note
Use this workbook as an operational planning tool, not a legal opinion.
The highest-value outcome is a small number of clear, owned fixes. If you want PipeWise to turn your results into a tailored remediation roadmap, use the purchase confirmation page to book a follow-up consultation after you complete the workbook.