Office of Pipeline Safety

Integrity Management Inspection Process

Louisiana Pipeline Safety SeminarAugust 2003

Office of Pipeline Safety

IM Inspection ScheduleJanuary – April, 2002 “Quick Hit” Segment

Identification InspectionsSeptember – October, 2002 4 Inspections – First

Application of Protocols

January, June 2003 OPS IM Inspection Lessons Learned Meetings

February – August, 2003 17 Additional Inspections Conducted

July, 2003 – Estimate mid 2004

Pilot “Small” Operator Inspections

September 2003 – Early 2004 Remaining “Large” Operator Inspections

March, 2004 Begin Large Operator Re-inspections

Office of Pipeline Safety

Review of Quick Hit Inspections

Segment Identification and Completeness Check:

Objectives

Confirm Segments Affecting HCAs have been Identified (Required by 12/31/01)

Assure Baseline Assessment Plans and IM Frameworks have Essential Elements

Office of Pipeline Safety

Review of Quick Hit Inspections

40 Inspections

~ 159,000 Miles of Pipe

Percentage of Operator Mileage Identified that “Could Affect” HCAs = 39%

• Median – 44%

• Maximum – 100%

• Minimum – 0%

Office of Pipeline Safety

Presentation Topics

Integrity Management Inspection

Scope

Inspection Preparation

Overview of Example Inspection

Inspection Documentation

Office of Pipeline Safety

Integrity Management Inspection Scope

Separate from Standard Inspections

All Integrity Management Program Requirements in 195.452

• Baseline Assessment Plans

• Integrity Management Program Elements

• Follow-up on Segment Identification Issues from “Quick Hit” Inspections

Office of Pipeline Safety

Inspection Scope (cont’d)

Program Implementation, including:

• Integrity Assessments Completed

• Repairs

• Preventive and Mitigative Actions

• Performance Measures

Office of Pipeline Safety

Presentation Topics

Integrity Management Inspection

Scope

Inspection Preparation

Overview of Example Inspection

Inspection Documentation

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Inspection Preparation Coordination/Interaction with

Operator Inspection Logistics

• Inspection Physical Arrangements• Team Size and Composition• Inspection Topics • Operator Personnel Needed• Inspection Schedule and Estimated Duration for each

Phase of Inspection• IMDB Access for Operator• Inspection Team Access to Records, Documentation

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Inspection Preparation Coordination/Interaction with

Operator Review:

• Operator Assets (Pipelines and Facilities) within Scope of Inspection• QH Inspection Issues

Obtain:• System Maps• IM Program Documentation

Provide:• Inspection Protocols• Performance Data Form• In-line Inspection Results Summary Form• System Leak Detection Capabilities Form

Office of Pipeline Safety

OPS IM Team Preparation Summarize

• Accident/Failure History

• Recent, Significant Compliance Concerns

• Segment Identification Inspection Results

• Notification Information: IMDB

• State and Region Identified Issues

Specific Areas for Segment Identification Verification

Review with Team Members at Team Pre-Inspection Meeting

Office of Pipeline Safety

Current Inspection Team Composition (OPS)

Multi-Region Teams

• Reflective of Regions with Operator’s facilities

Inspectors with IM Inspection Experience

Rotate in New OPS Inspectors Over Time

• Inspectors Receive Set of IM Courses

• On-the-Job Training with Experienced IM Inspectors

Office of Pipeline Safety

Inspection Preparation:Team Composition (States)

States to be Invited by Operators to Inspection

• Operator has Facilities in State

• States with Interstate Agent Status

• States with Intrastate Programs

State Participants Will Also Complete IM Training

State Input to Inspection Encouraged

Office of Pipeline Safety

Presentation Topics

Integrity Management Inspection Scope

Inspection Preparation

Overview of Example Inspection

Inspection Documentation

Office of Pipeline Safety

Overview of Example Large Operator Inspection

Duration: 4-9 Days

Could be Longer for Operators with:

• Large Systems

• Large Number of Assessments Completed

• Geographically Separated Operating Units

At least 1 week Separation between First and Second Weeks

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Example IM InspectionDay 1

Begin Monday Afternoon

Introductions/Review Agenda

Operator Introductory Presentation of IM Program

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Example IM InspectionDay 2

Segment Identification Review

• Methods

• Address Issues from Quick Hit Inspections

• Additional Verification of Segments

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Example IM InspectionWeek 1, Day 3

Risk Analysis Process

Completed Risk Analysis Results

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Example IM InspectionWeek 1, Day 4

Baseline Assessment Plan Review

• Approach for Assessment Method Selection• Segment Prioritization Methodology

• Segment Specific Threats & Assessment Methods

OPS Team Caucus to Prepare Feedback

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IM InspectionsConclusion of Week 1, Day 5

Week 1 Close Out Meeting with Operator

Inspection Issues from First Week

Conclude Week 1 Noon Friday

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Example IM InspectionWeek 2, Day 1

Start Monday Afternoon

Discussion/Resolution of Week 1 Issues

Integrity Assessment Results Approach

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Example IM InspectionWeek 2, Day 2

Integrity Assessment Results Approach (cont’d)

Verify Schedule is Met for Completed Assessments

Results from Completed Assessments

Repair & Mitigation Records for Conditions Identified through Integrity Assessments

Office of Pipeline Safety

Example IM InspectionWeek 2, Day 3

Approach to Evaluate Additional Preventive & Mitigative Actions

Preventive & Mitigative Action Decisions & Implementation

Evaluation and Implementation of EFRDs & Leak Detection System Enhancements

Office of Pipeline Safety

Example IM Inspection Week 2, Day 4

Continual Integrity Assessment and Evaluation Approach

Performance Evaluation Approach

OPS Team Caucus to Prepare Feedback

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Example IM Inspection Week 2, Days 5

Exit Interview• Follow-up to Inspection Issues• Define Follow-up Field Verifications

and Subsequent Inspections (if needed)

Complete Week 2 Noon Friday

Office of Pipeline Safety

General Inspection Subjects Team can use Subsets of Inspectors for

Specific Tasks (Team Lead Discretion) Team may Conduct Daily (or more frequent)

Debriefs• Summarize Day’s Results & Plan Next Day’s

Activities• Identify Potential Issues

Team will Keep Operator Informed about Changes to the Schedule

Order of Inspection and Time Allotted are Guides Only

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Different Approaches for Conducting Inspection Using Protocols

Sequential Completion of Protocol Questions

Operator Presentations and Follow-up Questions

General Discussion of Each Program Element, guided by Protocol Questions and Topics

Take Time to Read Program Documentation

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Supplemental Guidance

Support Consistency for Performance-based Requirements Evaluations

Reference for Teams During InspectionsReflect OPS Knowledge Base Acquired

during Inspections• Continues to Improve

• Practical Guidance for Inspecting Operator Processes

• Compliance Basis

Office of Pipeline Safety

Presentation Topics

Integrity Management Inspection Scope

Inspection Preparation

Overview of Example Inspection

Inspection Documentation

Office of Pipeline Safety

Inspection Documentation

Responses to Protocol Questions

• Inspection Notes

• Potential Issues

Inspection Summary Report

Inspection Executive Summary

Enforcement Documents

Performance Related Data

Potential Improvements to Protocols and Guidance