1. NAPSR/OPS Work Group on Small System Inspections Bruce Hansen OPS Program Development May 17, 2005

2. NAPSR/OPS Work Group Why it was formed Why it was formed Who was involved Who was involved Work Group activities Work Group activities Accomplishments Accomplishments

3. Develop an inspection approach applicable to smaller hazardous liquid systems Develop an inspection approach applicable to smaller hazardous liquid systems Design an approach that can be used by state and federal inspectors. Design an approach that can be used by state and federal inspectors. Achieve an appropriate level of consistency. Achieve an appropriate level of consistency. Establish a model that could be applied for intrastate gas IM Establish a model that could be applied for intrastate gas IM Why It Was Formed

4. A flexible inspection process A flexible inspection process An inspection approach which adjusted the level of resource expended to: An inspection approach which adjusted the level of resource expended to: risk of operations risk of operations complexity and extent of operator systems complexity and extent of operator systems operator’s organization structure and IM methods operator’s organization structure and IM methods Work Group Goals

5. Maximize training opportunities for state and federal inspectors. Maximize training opportunities for state and federal inspectors. Maximize coordination between federal and state agencies to promote efficient use of inspection resources. Maximize coordination between federal and state agencies to promote efficient use of inspection resources. Work Group Goals

6. Comprised mostly of state inspectors Comprised mostly of state inspectors OPS coordination OPS coordination Contract support Contract support Chuck MacDonald, CA SFM Danny Nichols, TX RRC Dana Arabie, LA DNR Hossein Monfared, OPS WR Pat Raichel, NY DPS Bruce Hansen, OPS HQ Tommy Lancaster, AL PSC DeWitt Burdeaux, TSI The Participants

7. Evaluated “large operator” IM inspection process and adjusted for small systems Evaluated “large operator” IM inspection process and adjusted for small systems Used characteristics of small systems to develop guidance for: Used characteristics of small systems to develop guidance for: inspection scheduling inspection scheduling identifying inspection focus areas identifying inspection focus areas effective inspection resource allocation effective inspection resource allocation Key Workgroup Activities

8. Developed protocol-based small system inspection process Developed protocol-based small system inspection process Conducted inspections to test the process Conducted inspections to test the process Work group member states initially Work group member states initially OPS Regions and other liquid program states OPS Regions and other liquid program states Key Workgroup Activities

9. Developed and conducted training to communicate approach Developed and conducted training to communicate approach Provided opportunities for “OJT” to assist inspectors new to IM Provided opportunities for “OJT” to assist inspectors new to IM Key Workgroup Activities

10. Work Group Products Work Group Products Condensed protocol form Condensed protocol form Training aids to explain protocol structure and organization (fish bone diagrams) Training aids to explain protocol structure and organization (fish bone diagrams) Simple system prioritization example approach Simple system prioritization example approach Guidance for small system IM inspections Guidance for small system IM inspections Accomplishments

11. Work Group Products (cont.) Work Group Products (cont.) State Verification Inspection process State Verification Inspection process Simplified inspection documentation options Simplified inspection documentation options Minimum information reporting guidelines Minimum information reporting guidelines Accomplishments

12. ~ 100 small system inspections conducted through March 2005 (some interstate systems) ~ 100 small system inspections conducted through March 2005 (some interstate systems) 1.2 to 498 miles 1.2 to 498 miles Acquisitions can impact inspection approach as well as operator preparedness Acquisitions can impact inspection approach as well as operator preparedness Short refinery and delivery lines, as well as longer transmission lines Short refinery and delivery lines, as well as longer transmission lines Small System Inspection Progress

13. Inspection duration: ½ to 3 days Inspection duration: ½ to 3 days Target date to complete initial IM inspections for all liquid operators is end of 2005 Target date to complete initial IM inspections for all liquid operators is end of 2005 Small System Inspection Progress

14. Issued Work Group Final Report and completed work products Issued Work Group Final Report and completed work products Communicated work group results to state programs not represented on the work group Communicated work group results to state programs not represented on the work group Limited inspection assistance (OJT) is still available Limited inspection assistance (OJT) is still available Work Group Completion Activities

15. Established work group scope, goals, and work products Established work group scope, goals, and work products Review of gas IM training materials Review of gas IM training materials Protocol screening questions Protocol screening questions Direct Assessment inspection approaches Direct Assessment inspection approaches Gas IM state verification process Gas IM state verification process Intrastate Gas Inspection Approach document Intrastate Gas Inspection Approach document Intrastate Gas IM Work Group

16. The End