Overview of Key Rule Features Pipeline Integrity Management in High Consequence Areas for Hazardous Liquid Operators Overview of Key Rule Features Workshop on the Integrity Management Rule for Large Liquid Pipelines Skip Brown August 7, 2001

Integrity Management Rule Objectives Accelerate Assessments of Lines in High Consequence Areas (HCAs) Improve Company Integrity Management Systems Improve Government Role in Reviewing Integrity Plans and Programs Increase Public Assurance in Pipeline Safety

To Whom Does this Rule Apply? Hazardous Liquid Operators who Own or Operate 500 or More Miles of Pipeline Facilities that are Jurisdictional to Part 195

What are HCAs for Hazardous Liquid Pipelines? Unusually Sensitive Areas of Environment (see Part 195.6) High Population Areas and Other Populated Areas Commercially Navigable Waterways

What must an Integrity Management (IM) Program include? Identification of Segments that Could Affect HCAs (12/31/01) Baseline Assessment Plan (3/31/02) Framework for Implementing IM Program Elements (3/31/02)

What IM Program Elements are Required by the Rule? Identifying Segments that Could Impact HCAs Conducting Periodic Integrity Assessments Reviewing Assessment Results by Qualified Personnel Making Mitigation and Repair Decisions

What IM Program Elements Are Required by the Rule? Integrating and Analyzing Risk Information Identifying and Evaluating Additional Risk Controls Measuring Program Performance H M Consequences L L M H Likelihood of Occurrence Highest Risk Lowest

What Should be in an IM Framework? Address All IM Program Elements Defined in Rule Describe Current Processes Lay Out Plan for IM Program Element Improvements

Segment Identification Obtain HCA Maps Determine Segment Boundaries where Spill Could Affect HCA Consider Local Factors such as Topography Consider System Design and Operation Characteristics Utilize Field Knowledge of Local Conditions Document Analysis and Key Assumptions

What Should be in the Baseline Assessment Plan? For each segment: Assessment Method(s) In-line Inspection Tool(s) Corrosion Deformation Pressure Testing Other Technology – OPS Notification Required Assessment Provisions Apply Only to Line Pipe

What Should be in the Baseline Assessment Plan? For each segment: Schedule identifying when segments will be assessed Basis for assessment method and schedule Assessments after 1/1/96 can be used for baseline 50% of mileage completed by 9/30/04 All segments by 3/31/08 Highest risk segments assessed first

Keeping the Baseline Assessment Plan Up-to-Date Reflect Insights from: Integrity Assessments Risk Analysis Operating Experience Apply New Technology Address Newly Identified HCAs Document and Retain the Basis for Plan Changes

Prioritizing Segments for Assessment Scheduling Use Existing Assessment Results Consider Segment-specific Risk Factors that Affect Likelihood and Consequences Documentation: Approach and Key Assumptions Segment-specific Integrity Threats Relative Rankings of Segments

Implementing the Assessment Plan Perform Assessments Integrate Results with Other Information Prepare Excavation and Repair Schedule Take Appropriate Mitigation Measures

Implementing the Assessment Plan Integrate Information into Future Risk Analysis Determine Timing and Method for Next Assessment Interval  5 Years Update Assessment Plan

Integrating Data Integrity Assessment Results Evaluation Common reference system Comparisons and analysis Risk Assessment Includes integrity assessment results Comprehensive Investigative

Evaluate Need for Additional Protection Update Risk Analysis Identify Additional Risk Control Opportunities Controls Aimed at Segment’s Highest Risks Leak Detection System Enhancements Emergency Flow Restricting Devices Evaluate Risk Reduction Document Bases for Management Decisions

Evaluating Program Performance Critical Self-examination Integrity Assessment Tools and Practices Management Systems Root Cause Analysis of Near Misses and Failures Performance Measures Feedback and Continuous Improvement

Rule Requires Operators to Notify OPS if They: Use a Technology other than Pigging or Pressure Testing Are Unable to Meet Repair Schedule Requirements, and Cannot Reduce Pressure Establish an Assessment Interval Greater than 5 Years

Integrity Management Program Documentation Baseline Assessment Plan and Revisions IM Framework Documentation of Processes for Each Program Element IM Program Performance Evaluation Findings and Performance Measures

Integrity Management Program Documentation Integrity Assessment Results Excavation and Repair Schedules Repair and Mitigation Records Records of Additional Preventive and Mitigative Actions Taken to Protect HCAs

Integrity Management Program Documentation Risk Assessment Results Evaluation of: Leak Detection System Capability Need for Emergency Flow Restricting Devices Justification for: Use of Other Assessment Methods Extending Assessment Interval beyond 5 Years Inability to Meet Repair Schedule Requirements

Summary Comments Assessment Requirements will Improve Understanding of Pipe Condition in HCAs Improvement in IM Systems is Key to Compliance with New Rule Information Integration and Risk Analysis are Critical Program Elements Improved Performance Results from a Commitment to Continuous Improvement