Office of Pipeline Safety Integrity Management Inspection Process Louisiana Pipeline Safety Seminar August 2003

Office of Pipeline Safety IM Inspection Schedule January – April, 2002 “Quick Hit” Segment Identification Inspections September – October, Inspections – First Application of Protocols January, June 2003OPS IM Inspection Lessons Learned Meetings February – August, Additional Inspections Conducted July, 2003 – Estimate mid 2004 Pilot “Small” Operator Inspections September 2003 – Early 2004 Remaining “Large” Operator Inspections March, 2004 Begin Large Operator Re-inspections

Office of Pipeline Safety Review of Quick Hit Inspections Segment Identification and Completeness Check: Objectives  Confirm Segments Affecting HCAs have been Identified (Required by 12/31/01)  Assure Baseline Assessment Plans and IM Frameworks have Essential Elements

Office of Pipeline Safety Review of Quick Hit Inspections  40 Inspections  ~ 159,000 Miles of Pipe  Percentage of Operator Mileage Identified that “Could Affect” HCAs = 39% Median – 44% Maximum – 100% Minimum – 0%

Office of Pipeline Safety Presentation Topics  Integrity Management Inspection Scope  Inspection Preparation  Overview of Example Inspection  Inspection Documentation

Office of Pipeline Safety Integrity Management Inspection Scope  Separate from Standard Inspections  All Integrity Management Program Requirements in Baseline Assessment Plans Integrity Management Program Elements Follow-up on Segment Identification Issues from “Quick Hit” Inspections

Office of Pipeline Safety Inspection Scope (cont’d)  Program Implementation, including: Integrity Assessments Completed Repairs Preventive and Mitigative Actions Performance Measures

Office of Pipeline Safety Presentation Topics  Integrity Management Inspection Scope  Inspection Preparation  Overview of Example Inspection  Inspection Documentation

Office of Pipeline Safety Inspection Preparation Coordination/Interaction with Operator  Inspection Logistics Inspection Physical Arrangements Team Size and Composition Inspection Topics Operator Personnel Needed Inspection Schedule and Estimated Duration for each Phase of Inspection IMDB Access for Operator Inspection Team Access to Records, Documentation

Office of Pipeline Safety Inspection Preparation Coordination/Interaction with Operator  Review: Operator Assets (Pipelines and Facilities) within Scope of Inspection QH Inspection Issues  Obtain: System Maps IM Program Documentation  Provide: Inspection Protocols Performance Data Form In-line Inspection Results Summary Form System Leak Detection Capabilities Form

Office of Pipeline Safety OPS IM Team Preparation  Summarize Accident/Failure History Recent, Significant Compliance Concerns Segment Identification Inspection Results Notification Information: IMDB State and Region Identified Issues  Specific Areas for Segment Identification Verification  Review with Team Members at Team Pre- Inspection Meeting

Office of Pipeline Safety Current Inspection Team Composition (OPS)  Multi-Region Teams Reflective of Regions with Operator’s facilities  Inspectors with IM Inspection Experience  Rotate in New OPS Inspectors Over Time Inspectors Receive Set of IM Courses On-the-Job Training with Experienced IM Inspectors

Office of Pipeline Safety Inspection Preparation: Team Composition (States)  States to be Invited by Operators to Inspection Operator has Facilities in State States with Interstate Agent Status States with Intrastate Programs  State Participants Will Also Complete IM Training  State Input to Inspection Encouraged

Office of Pipeline Safety Presentation Topics  Integrity Management Inspection Scope  Inspection Preparation  Overview of Example Inspection  Inspection Documentation

Office of Pipeline Safety Overview of Example Large Operator Inspection  Duration: 4-9 Days  Could be Longer for Operators with: Large Systems Large Number of Assessments Completed Geographically Separated Operating Units  At least 1 week Separation between First and Second Weeks

Office of Pipeline Safety Example IM Inspection Day 1  Begin Monday Afternoon  Introductions/Review Agenda  Operator Introductory Presentation of IM Program

Office of Pipeline Safety Example IM Inspection Day 2  Segment Identification Review Methods Address Issues from Quick Hit Inspections Additional Verification of Segments

Office of Pipeline Safety Example IM Inspection Week 1, Day 3  Risk Analysis Process  Completed Risk Analysis Results

Office of Pipeline Safety Example IM Inspection Week 1, Day 4  Baseline Assessment Plan Review Approach for Assessment Method Selection Segment Prioritization Methodology Segment Specific Threats & Assessment Methods  OPS Team Caucus to Prepare Feedback

Office of Pipeline Safety IM Inspections Conclusion of Week 1, Day 5  Week 1 Close Out Meeting with Operator  Inspection Issues from First Week  Conclude Week 1 Noon Friday

Office of Pipeline Safety Example IM Inspection Week 2, Day 1  Start Monday Afternoon  Discussion/Resolution of Week 1 Issues  Integrity Assessment Results Approach

Office of Pipeline Safety Example IM Inspection Week 2, Day 2  Integrity Assessment Results Approach (cont’d)  Verify Schedule is Met for Completed Assessments  Results from Completed Assessments  Repair & Mitigation Records for Conditions Identified through Integrity Assessments

Office of Pipeline Safety Example IM Inspection Week 2, Day 3  Approach to Evaluate Additional Preventive & Mitigative Actions  Preventive & Mitigative Action Decisions & Implementation  Evaluation and Implementation of EFRDs & Leak Detection System Enhancements

Office of Pipeline Safety Example IM Inspection Week 2, Day 4  Continual Integrity Assessment and Evaluation Approach  Performance Evaluation Approach  OPS Team Caucus to Prepare Feedback

Office of Pipeline Safety Example IM Inspection Week 2, Days 5  Exit Interview Follow-up to Inspection Issues Define Follow-up Field Verifications and Subsequent Inspections (if needed)  Complete Week 2 Noon Friday

Office of Pipeline Safety General Inspection Subjects  Team can use Subsets of Inspectors for Specific Tasks (Team Lead Discretion)  Team may Conduct Daily (or more frequent) Debriefs Summarize Day’s Results & Plan Next Day’s Activities Identify Potential Issues  Team will Keep Operator Informed about Changes to the Schedule  Order of Inspection and Time Allotted are Guides Only

Office of Pipeline Safety Different Approaches for Conducting Inspection Using Protocols  Sequential Completion of Protocol Questions  Operator Presentations and Follow-up Questions  General Discussion of Each Program Element, guided by Protocol Questions and Topics  Take Time to Read Program Documentation

Office of Pipeline Safety Supplemental Guidance  Support Consistency for Performance- based Requirements Evaluations  Reference for Teams During Inspections  Reflect OPS Knowledge Base Acquired during Inspections Continues to Improve Practical Guidance for Inspecting Operator Processes Compliance Basis

Office of Pipeline Safety Presentation Topics  Integrity Management Inspection Scope  Inspection Preparation  Overview of Example Inspection  Inspection Documentation

Office of Pipeline Safety Inspection Documentation  Responses to Protocol Questions Inspection Notes Potential Issues  Inspection Summary Report  Inspection Executive Summary  Enforcement Documents  Performance Related Data  Potential Improvements to Protocols and Guidance