Office of Pipeline Safety Remedial Action Review Protocol Integrity Management Workshop July 23-24, 2002

Office of Pipeline Safety Protocol Objectives Ensure operator’s remediation process is adequate to ensure safety and environmental protection Determine operator has implemented process effectively

Office of Pipeline Safety Program Element Requirement § (h) -- What actions must an operator take to address integrity issues? (1) General requirements. °take prompt action to address all anomalous conditions °remediate those that could reduce a pipeline’s integrity °demonstrate remediation will ensure long-term integrity of the pipeline

Office of Pipeline Safety Program Element Requirement § (h) (2) Discovery when operator has adequate information to determine condition presents a threat to integrity no later than 180 days after an integrity assessment

Office of Pipeline Safety Remediation Process Review Is process formally documented, reviewed and approved? Does process clearly document actions required and responsibilities? Does the process address all of the requirements found in § (h)? Does data feed back into the operator’s other integrity-related processes?

Office of Pipeline Safety Remediation Process Review Does process assure compliance with § ? °should address operator’s procedures for making repairs °must ensure repairs are made in a safe manner °should address applicable requirements for a design and construction noted in §195 Subparts C and D, respectively °should incorporate existing, recognized industry practices and standards for pipeline repairs

Office of Pipeline Safety Process Implementation Review Has the operator implemented its remediation process? Was a prioritized schedule prepared? Was a operating pressure reduced or pipeline shut down for all Immediate Repair Conditions? Were temporary reductions in operating pressures calculated appropriately?

Office of Pipeline Safety Process Implementation Review Were changes to the original remediation schedule handled appropriately? Were technical basis and justification for schedule changes valid? Was remediation accomplished in accordance with the operator’s process and procedures requirements?

Office of Pipeline Safety Remediation Schedule Should be consistent with § (h) (3) and (4) requirements based on severity of identified conditions Operators should consider other factors in prioritizing within those severity categories For all conditions, clock starts on day of discovery

Office of Pipeline Safety Remediation Schedule If remediation schedule cannot be met and operator cannot provide safety through a temporary reduction in operating pressure, operator must notify OPS

Office of Pipeline Safety Immediate Repair Conditions Operators MUST temporarily reduce operating pressure or shut down the pipeline until repairs are completed Pressure reductions °must be based on pressures pipe has actually experienced °must be calculated using the formula in B31.4, Section 451.7, if applicable, or engineering justification if not. °cannot exceed 365 days without further remedial action

Office of Pipeline Safety Immediate Repair Conditions Temporary pressure reductions should be determined and implemented immediately upon discovery “Immediately” being, as soon as it can practically be accomplished

Office of Pipeline Safety Remediation Methods Areas of inspection will include: Excavation Plans Repair methods & criteria Procedures & personnel qualification (welding, NDE, NDT)

Office of Pipeline Safety Expectations Formal documentation of remediation process including copies of reference procedures and documents Inclusion of requirements consistent with § (h) Use of repair methods consistent with industry standards Documentation of excavation and repairs