Integrity Management Inspection Process Don Moore, OPS Central Region

Office of Pipeline Safety What Approach Did OPS Take? Communicate with Industry/Stakeholders Develop Detailed Inspection Protocols Training of Inspectors Consistently Apply Inspection Process Development of Enforcement Approach

Office of Pipeline Safety Implementing IM Website – Rule and Federal Register Notices – FAQs (linked to sections of the rule) – Inspection Protocols – Fact Sheets and Other References – Public Meeting Presentation Material – Online Notification Submittal and Status – Opportunity to Submit Comments to OPS

Office of Pipeline Safety Frequently Asked Questions Clarify rule requirements – Carefully Reviewed to Ensure Consistency with Intent of Rule Provide information on inspection program Communicate OPS Expectations Opportunity for Public Input Can be sorted to identify recent updates

Office of Pipeline Safety Public Workshops August Houston – Rule Requirements – NPMS and the Identification of HCAs – API-1160 – Segment Identification Expectations July 2002 – Houston – Segment Identification Inspection Results – Comprehensive Protocol Review – FAQs – Enforcement Approach

Office of Pipeline Safety Inspection Protocol Development Experience from Risk Management and SII Programs Insights from Part 195 Inspection Experience, Conducting System Type Inspections, and Accident Investigations Information Obtained from “Completeness Check” Portion of Segment Identification Inspections

Office of Pipeline Safety Inspection Protocol Development, continued Input from IM Inspector Working Meetings Guidance from Subject Matter Experts Protocol Effectiveness Reviews at Periodic Lessons Learned Meetings

Office of Pipeline Safety Protocol Content Organized by Program Elements in 452 (f), Protocols contain questions to: – Evaluate IM Process and Methods – Review Process Implementation – Evaluate Operator Understanding of Integrity Issues and Actions Taken to Protect HCAs Guidance for each question identifies: – Prescriptive requirements – Characteristics of an effective program

Office of Pipeline Safety Inspector Training Classroom Training: Specific courses on the following specialized subjects: – Rule Requirements – Inspection Protocols – Management Systems and Risk Analysis – Pipeline Materials and Defects – Welding Technology – In-Line Inspection – Corrosion Control – SCADA and Leak Detection Mentoring program for new inspectors

Office of Pipeline Safety Inspection Process Pre-Inspection Information Gathering Inspection Duration 1 – 2 weeks, depending on: – Size and complexity of pipeline system(s) – HCA exposure – Number of assessments completed – Complexity of program processes and completeness of documentation Operator IM Program Presentation

Office of Pipeline Safety Inspection Process, continued Protocol Guided Inspection – Protocols support an investigative, analytical review – are not a checklist – Process and Documentation Operator understanding of process – Implementation and Records Operator understanding of significant integrity threats and how they are being managed Exit interview Documentation – Summary Report

Office of Pipeline Safety Inspection Participants Government – Interstate pipeline OPS (multi-Region teams for large operators) Interstate agents, if applicable – Intrastate pipeline OPS or State program

Office of Pipeline Safety Inspection Participants Operator – IM Program Manager – Individuals Involved in IM Program: Operations Maintenance Risk Assessment Assessment Results Evaluation Corrosion Control Leak Detection – Outside consultants, if used

Office of Pipeline Safety Documentation Reviewed During Inspection IM Program Description, latest revision Baseline Assessment Plan O&M Manual Procedures, Guidelines, and Technical Reports referenced by the IM Program description

Office of Pipeline Safety IM Program Records Reviewed During Inspection Assessment Results – Preliminary and Final ILI Vendor Reports – Operator evaluation of ILI Results including the Integration of other Data and Information – Hydrostatic Test Reports Results of ILI Tool Data Evaluation – Date of Discovery – Anomaly characterization and categorization

Office of Pipeline Safety IM Program Records Reviewed During Inspection, continued Repair Records – Date of repair – Location of Repair – Type of Repair Pressure Reduction Records – Immediate repair conditions – 60 and 180 day anomalies for which remediation can not be accomplished in required time

Office of Pipeline Safety Inspection Process Improvements – Inspector Lessons Learned Meetings Common industry problems, inspection experiences, and unique insights Effectiveness of Protocols Areas where additional guidance is needed –New or improved FAQs –Areas where technical expertise should be brought in

Office of Pipeline Safety Enforcement Objectives for IM Assure operators are developing and implementing IM Programs consistent with the rule: – Performing integrity assessments in accordance Assessment Plans – Addressing issues discovered through assessments – Developing and implement required IM program elements to provide improved protection for HCAs Foster improvements in IM Programs as they proceed from a “Framework” to a mature program

Office of Pipeline Safety OPS Enforcement Approach Enforcement Instruments the Same as for Standard Inspections – Notice of Amendment (NOA) – Warning Letter – Notice of Probable Violation (NOPV) Proposed Compliance Order Proposed Civil Penalty – Corrective Action Order Feedback also provided through Exit Interviews, Inspection Summary Reports, and Letters of Concern

Office of Pipeline Safety Enforcement for Prescriptive Requirements Rule has clearly required actions and time frames – Segment Identification – Baseline Assessment Plan and Framework Preparation – Baseline Assessment Methods & Schedules – Mitigation/Repair Time Frames – Re-assessment Intervals NOPV and Warning Letter used to address probable violations

Office of Pipeline Safety Enforcement for Process-based Requirements Process-based Requirements Involve Development of IM Programs – In-Line Inspection Results Review and Data Integration – Risk Analysis Variety of Acceptable Processes Rule allowed for a “framework” maturing into a fully developed program These characteristics dictated a different approach for enforcement

Office of Pipeline Safety Guiding Principles for Process- based Requirement Enforcement Foster Development of Mature and Effective IM Programs, Processes & Tools No Rigid “Standard” for IM Program Acceptance Structured Inspection Protocols Focus on Basic Requirements & Visible, Demonstrable Efforts to Comply Strive for Consensus among inspection teams

Office of Pipeline Safety Process-based Requirement Enforcement Extensive use of NOAs & Letters of Concern NOPVs restricted to: – where little or no evidence of process development was presented, – omission of rule requirements for program elements (e.g., required risk factors, ignoring available data), or – technical errors and unjustified assumptions resulting in: Inadequate understanding of risk conditions; or Potential for significant impact on the level of protection provided to HCAs.

Office of Pipeline Safety Enforcement Approach is Still Evolving Revised our approach to close NOAs based on experience from Segment Identification Inspections – Eliminated requirement for “order directing procedure amendments ” Continuing to reengineer our internal processes to process cases faster – Developing detailed guidance for IM enforcement decisions that will expedite actions recommended by the Region inspection teams

Office of Pipeline Safety Re-establish Enforcement Program’s long term goals and objectives – Logically structuring regulatory strategies to achieve goals – Defining and implementing actions to achieve strategies – Creating metrics to evaluate enforcement program effectiveness Enforcement Approach is Still Evolving, continued

Office of Pipeline Safety Summary – The Path We’ve Taken Extensive Industry/Stakeholder Communication Detailed Inspection Protocols Broad-based Inspector Training in New Areas Internal Efforts to Assure Consistency in the Inspection Process Evolving Enforcement Approach

Next Up – What we learned on our Journey