1. Lessons Learned from Integrity Management Inspections Byron Coy – OPS Eastern Region Derick Turner – OPS Southern Region May 17, 2005

2. Summary of Experience to Date Operators generally understand and are implementing the assessment provisions of the rule Operators generally understand and are implementing the assessment provisions of the rule Operators are generally able to meet repair deadlines Operators are generally able to meet repair deadlines

3. Progress is needed in development of some IM Program Elements, but this is expected Progress is needed in development of some IM Program Elements, but this is expected Improved performance results from senior management support and a commitment to continuous improvement Improved performance results from senior management support and a commitment to continuous improvement Summary of Experience to Date

4. OPS successfully implemented a programmatic inspection approach (vs. “yes/no” checklist) OPS successfully implemented a programmatic inspection approach (vs. “yes/no” checklist)  Measures to achieve consistency in identifying issues have been effective OPS Perspective on Inspection Process

5. Protocol application can be tailored to: Protocol application can be tailored to:  Risk  Leak history  Extent of HCA exposure  Pipeline system complexity  IM process maturity and sophistication  Conservatism in assumptions and methods  Organization structure and complexity OPS Perspective on Inspection Process

6. Operator interactions have been generally cooperative with open communication Operator interactions have been generally cooperative with open communication  OPS provided operators with significant and well- received feedback on areas for improvement OPS Perspective on Inspection Process

7. Enforcement approach strives to promote operator program development and ongoing improvement Enforcement approach strives to promote operator program development and ongoing improvement Inspection approach continues to improve Inspection approach continues to improve OPS Perspective on Inspection Process

8. Initial inspections may involve significant “education” for some operators of small systems Initial inspections may involve significant “education” for some operators of small systems Operators of small systems may be more likely to contract out significant portions of IM program development Operators of small systems may be more likely to contract out significant portions of IM program development Operator is still ultimately responsible Operator is still ultimately responsible General Inspection Observations

9. Program quality correlates better to corporate resources than pipeline mileage Program quality correlates better to corporate resources than pipeline mileage General Inspection Observations

10. Experience Everything from outlines to multi-volume documents Everything from outlines to multi-volume documents Evidence of compliance for completion sometimes missing Evidence of compliance for completion sometimes missingExpectations IM Plan Organization

11. Experience Everything from outlines to multi- volume documents Everything from outlines to multi- volume documents Evidence of compliance for completion sometimes missing Evidence of compliance for completion sometimes missing Expectations Do not regurgitate the rule Do not regurgitate the rule Not all processes have to be fully documented within the IMP – can be referenced Not all processes have to be fully documented within the IMP – can be referenced Process should support the implementation of a more consistent and thorough approach Process should support the implementation of a more consistent and thorough approach IM Plan Organization

12. Experience Buffer zones of several sizes Buffer zones of several sizes Some weak technical justifications Some weak technical justifications Overland spill transport models Overland spill transport models Simplifying assumptions for water transport Simplifying assumptions for water transport Segment Identification Expectations

13. Experience Buffer zones of several sizes Buffer zones of several sizes Some weak technical justifications Some weak technical justifications Overland spill transport models Overland spill transport models Simplifying assumptions for water transport Simplifying assumptions for water transport Segment Identification Expectations Technical justification is important Technical justification is important Elaborate approaches are not always necessary Elaborate approaches are not always necessary Use of field knowledge to capture all HCAs Use of field knowledge to capture all HCAs May not need major re- review May not need major re- review

14. Experience Most Plans satisfactory, but some did not include basic requirements – e.g., dates, assessment method, justification Most Plans satisfactory, but some did not include basic requirements – e.g., dates, assessment method, justification For ILI, Plans are structured around piggable sections – correlation with “could affect” segments sometimes difficult For ILI, Plans are structured around piggable sections – correlation with “could affect” segments sometimes difficultExpectations Baseline Assessment Plan

15. Experience Most Plans satisfactory, but some did not include basic requirements – e.g., dates, assessment method, justification Most Plans satisfactory, but some did not include basic requirements – e.g., dates, assessment method, justification For ILI, Plans are structured around piggable sections – correlation with “could affect” segments sometimes difficult For ILI, Plans are structured around piggable sections – correlation with “could affect” segments sometimes difficultExpectations Spreadsheet or table can suffice as the plan Spreadsheet or table can suffice as the plan 50% and 100% mileage requirements must be satisfied 50% and 100% mileage requirements must be satisfied Prioritization method can match complexity and risk of system used to establish a schedule Prioritization method can match complexity and risk of system used to establish a schedule Baseline Assessment Plan

16. Experience Broad spectrum of approaches – GIS- based analytical tools to nothing at all Broad spectrum of approaches – GIS- based analytical tools to nothing at all Data integration varies from computer based to informal process to none Data integration varies from computer based to informal process to noneExpectations Integrity Assessment Results Review

17. Experience Broad spectrum of approaches – GIS- based analytical tools to nothing at all Broad spectrum of approaches – GIS- based analytical tools to nothing at all Data integration varies from computer based to informal process to none Data integration varies from computer based to informal process to noneExpectations Thorough review of vendor ILI reports by operator personnel Thorough review of vendor ILI reports by operator personnel Involve the experience/ expertise in the company Involve the experience/ expertise in the company Integration with non-ILI data Integration with non-ILI data Document cause of hydrotest failures Document cause of hydrotest failures Integrity Assessment Results Review

18. Experience Timely vendor reporting can be a problem Timely vendor reporting can be a problem Some lengthy times between deformation and metal loss tools Some lengthy times between deformation and metal loss tools Operators build in time to confirm defects are “real” (e.g., not previously repaired) Operators build in time to confirm defects are “real” (e.g., not previously repaired)Expectations “Discovery”

19. Experience Timely vendor reporting can be a problem Timely vendor reporting can be a problem Some lengthy times between deformation and metal loss tools Some lengthy times between deformation and metal loss tools Operators build in time to confirm defects are “real” (e.g., not previously repaired) Operators build in time to confirm defects are “real” (e.g., not previously repaired)Expectations Expect operators to promptly reduce pressure for immediate repair conditions Expect operators to promptly reduce pressure for immediate repair conditions Act on data from single tool if sufficient for discovery and 2 nd tool delayed Act on data from single tool if sufficient for discovery and 2 nd tool delayed Document why discovery extends beyond 180 days after assessment Document why discovery extends beyond 180 days after assessment “Discovery”

20. Experience Operators understand and are trying to meet repair deadlines Operators understand and are trying to meet repair deadlines Rule’s repair provisions not always in O&M procedures Rule’s repair provisions not always in O&M procedures Some notifications when schedule can not be met and pressure not reduced Some notifications when schedule can not be met and pressure not reducedExpectations Repair and Remediation

21. Experience Operators understand and are trying to meet repair deadlines Operators understand and are trying to meet repair deadlines Rule’s repair provisions not always in O&M procedures Rule’s repair provisions not always in O&M procedures Some notifications when schedule can not be met and pressure not reduced Some notifications when schedule can not be met and pressure not reduced Expectations Records should clearly show assessment, discovery, and repair dates Records should clearly show assessment, discovery, and repair dates Feedback to ILI analyst of actual excavated defect conditions and repair information Feedback to ILI analyst of actual excavated defect conditions and repair information Repair and Remediation

22. Experience Complicated mathematical models to SME approaches Complicated mathematical models to SME approaches Simple approaches for prioritizing segments; more detailed methods for looking at segment-specific threats Simple approaches for prioritizing segments; more detailed methods for looking at segment-specific threats Justification for assumptions lacking Justification for assumptions lackingExpectations Information/Risk Analysis

23. Experience Complicated mathematical models to SME approaches Complicated mathematical models to SME approaches Simple approaches for prioritizing segments; more detailed methods for looking at segment-specific threats Simple approaches for prioritizing segments; more detailed methods for looking at segment-specific threats Justification for assumptions lacking Justification for assumptions lackingExpectations Systematic process Systematic process Comprehensive consideration of threats Comprehensive consideration of threats Inclusion of facilities Inclusion of facilities Involvement of all relevant operator expertise/experience Involvement of all relevant operator expertise/experience Investigative approach Investigative approach Information/Risk Analysis

24. Experience Few operators had mature process for this element Few operators had mature process for this element Processes often not well developed or documented Processes often not well developed or documented Have seen few leak detection and EFRD evaluations Have seen few leak detection and EFRD evaluationsExpectations Preventive & Mitigative Measures

25. Experience Few operators had mature process for this element Few operators had mature process for this element Processes often not well developed or documented Processes often not well developed or documented Have seen few leak detection and EFRD evaluations Have seen few leak detection and EFRD evaluationsExpectations Consideration of potential preventive and mitigative actions – not assumption that existing programs are enough Consideration of potential preventive and mitigative actions – not assumption that existing programs are enough Documented, risk-based justification Documented, risk-based justification Leak Detection / EFRD analysis to be in place Leak Detection / EFRD analysis to be in place Preventive & Mitigative Measures

26. Experience Few operators considered periodic evaluations Few operators considered periodic evaluations Tendency to default to a 5 year assessment interval Tendency to default to a 5 year assessment intervalExpectations Continual Evaluation and Assessment

27. Experience Few operators considered periodic evaluations Few operators considered periodic evaluations Tendency to default to a 5 year assessment interval Tendency to default to a 5 year assessment intervalExpectations Baseline Plan transitions into an on-going assessment plan Baseline Plan transitions into an on-going assessment plan For some lines assessment more frequently than 5 years is appropriate For some lines assessment more frequently than 5 years is appropriate Continual Evaluation and Assessment

28. Experience Wide variation in how continuing evaluation is approached Wide variation in how continuing evaluation is approached Some interval extension notifications received by OPS Some interval extension notifications received by OPSExpectations Continual Evaluation and Assessment

29. Experience Wide variation in how continuing evaluation is approached Wide variation in how continuing evaluation is approached Some interval extension notifications received by OPS Some interval extension notifications received by OPSExpectations Available techniques for corrosion growth modeling, fatigue crack growth models may be useful Available techniques for corrosion growth modeling, fatigue crack growth models may be useful Sound basis for treatment of seam integrity susceptibility, SCC Sound basis for treatment of seam integrity susceptibility, SCC Continual Evaluation and Assessment

30. Experience Little attention given to this element Little attention given to this element Performance measures have mostly been those in API-1160 – sometimes less Performance measures have mostly been those in API-1160 – sometimes less Some good approaches to root cause analysis Some good approaches to root cause analysisExpectations IM Program Effectiveness

31. Experience Little attention given to this element Little attention given to this element Performance measures have mostly been those in API-1160 – sometimes less Performance measures have mostly been those in API-1160 – sometimes less Some good approaches to root cause analysis Some good approaches to root cause analysisExpectations Process in place by which the operator reviews its program effectiveness (e.g., internal and external audits, management reviews) Process in place by which the operator reviews its program effectiveness (e.g., internal and external audits, management reviews) Management awareness and support Management awareness and support IM Program Effectiveness

32. Common IM Program Issues

33. Segment Identification Issues

34. RankIssue Description 1 Failure to require use of local knowledge, field personnel input, and other sources to update HCA information 2 Failure to adequately document the segment identification results, process and assumptions 3 Failure to adequately justify the buffer size used to identify segments or facilities that could affect HCAs 4 Failure to perform adequate water transport analysis where applicable 5Failure to adequately identify and locate HCAs Segment Identification Issues

35. Baseline Assessment Plan Issues

36. RankIssue Description 1 Failure to technically justify why pre-70 LF ERW or lap-welded pipe is not susceptible to seam integrity issues 2 Failure to document the reasons for changes to the BAP 3Failure to technically justify assessment method Baseline Assessment Plan Issues

37. RankIssue Description 4 Failure to develop a BAP schedule that reflects the relative risk of the HCA affecting segments 5 Failure to adequately specify assessment method(s) for all segments in the BAP 5 Use of an incomplete risk evaluation for BAP scheduling that does not consider each of the relevant risk factors required by the rule Baseline Assessment Plan Issues

38. Assessment Results Issues

39. RankIssue Description 1 Failure to develop a process to qualify personnel reviewing assessment results 2 Failure to require the integration of other pertinent data in a timely manner, when evaluating assessment results 3 Failure to specify adequate vendor specifications including tool tolerances and timeframes for ILI reports Assessment Results Issues

40. RankIssue Description 4 Failure to address the integrity assessment results review requirements in the IM plan or procedures 5 Failure to provide adequate assurance through calibration/verification digs, or other means, that tool data is valid and suitable for integrity-related analysis Assessment Results Issues

41. Remedial Action Issues

42. RankIssue Description 1 Failure to adequately document compliance with repair rule criteria 2 Failure to require compliance with the ASME B31.4 Section 451.7 or document other acceptable pressure reduction methods when this code section is not applicable Remedial Action Issues

43. RankIssue Description 3 Failure to require implementation of time response requirements contained in the rule 4 Failure to require pressure reductions for immediate repairs 5Failure to require prioritization of anomalies for repair Remedial Action Issues

44. Information/Risk Analysis Issues

45. RankIssue Description 1 Failure to consider facilities (e.g., tanks) in risk analysis 2 Failure to develop a comprehensive risk analysis process or consider all required risk factors 3 Failure to require updates of the risk model for current conditions and environment 4 Failure to adequately document the risk analysis process 5 Failure to include explicit guidelines and process formality to support use of SME approach Information/Risk Analysis Issues

46. Preventive & Mitigative Issues

47. RankIssue Description 1 Failure to have a systematic, documented process to evaluate additional measures to protect HCAs 2Failure to have a documented EFRD needs analysis 3 Failure to document a leak detection evaluation process 4 Failure to require a documented justification for decisions regarding additional preventive and mitigative measures 5 Failure to consider risk analysis in making preventive and mitigative decisions Preventive & Mitigative Issues

48. Continual Assessment/Evaluation Issues

49. RankIssue Description 1 Failure to develop or document an adequate periodic evaluation process that meets rule requirements 2 Failure to consider all relevant information or develop adequate justification for reassessment intervals 3 Failure to consider all relevant information or provide an adequate explanation of re-assessment methods Continual Assessment/Evaluation Issues

50. RankIssue Description 4 Failure to develop or document a process for determining re-assessment intervals 5 Failure to specify appropriate intervals to periodically evaluate the pipeline risks 5 Failure to prohibit reassessment intervals that exceed five years without adequate technical justification or notification of OPS Continual Assessment/Evaluation Issues

51. Program Evaluation Issues

52. RankIssue Description 1 Failure to provide adequate detail in all or most areas of the IM Plan 2 Failure to develop adequate procedures for implementing the performance evaluation process 3 Failure to communicate the results of the Program Evaluation process to company personnel or third parties who need to make use of that information 4 Failure to specify document retention periods or distribution requirements in the IM Plan 5 Failure to require or perform root cause analyses of incidents that affect pipeline integrity Program Evaluation Issues

53. Three rule instances in which operators can notify Three rule instances in which operators can notify Use of “Other Technology” Use of “Other Technology” Inability to meet repair schedules or reduce pressure Inability to meet repair schedules or reduce pressure Interval longer than 5 years Interval longer than 5 years First notifications received in May 2002 First notifications received in May 2002 Notification Experience

54. Notifications by Type Notification Experience

55. Notifications by Pipeline Category 16 of the notifications for intrastate pipelines involved pipelines in Texas Notification Experience

56. Notifications by Disposition Notification Experience

57. Notifications by Operator A total of 26 operators have submitted notifications Notification Experience

58. More Information: http://primis.phmsa.dot.gov/iim/notifications.imd http://primis.phmsa.dot.gov/iim/notifications.imdOR Go to the Implementing Integrity Management (IIM) home page - http://primis.phmsa.dot.gov/iim Go to the Implementing Integrity Management (IIM) home page - http://primis.phmsa.dot.gov/iim Select Notifications/Notification Listing Select Notifications/Notification Listing Notification Experience

59. The End