1. 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

2. 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

3. 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

4. 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

5. 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)

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

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

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

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

17. 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

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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