Office of Pipeline Safety Integrity Management Inspection Process Louisiana Pipeline Safety Seminar August 2003
Jan 06, 2016
Office of Pipeline Safety
Integrity Management Inspection Process
Louisiana Pipeline Safety SeminarAugust 2003
Office of Pipeline Safety
IM Inspection ScheduleJanuary – April, 2002 “Quick Hit” Segment
Identification InspectionsSeptember – October, 2002 4 Inspections – First
Application of Protocols
January, June 2003 OPS IM Inspection Lessons Learned Meetings
February – August, 2003 17 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 195.452
• 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 InspectionDay 1
Begin Monday Afternoon
Introductions/Review Agenda
Operator Introductory Presentation of IM Program
Office of Pipeline Safety
Example IM InspectionDay 2
Segment Identification Review
• Methods
• Address Issues from Quick Hit Inspections
• Additional Verification of Segments
Office of Pipeline Safety
Example IM InspectionWeek 1, Day 3
Risk Analysis Process
Completed Risk Analysis Results
Office of Pipeline Safety
Example IM InspectionWeek 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 InspectionsConclusion 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 InspectionWeek 2, Day 1
Start Monday Afternoon
Discussion/Resolution of Week 1 Issues
Integrity Assessment Results Approach
Office of Pipeline Safety
Example IM InspectionWeek 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 InspectionWeek 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 InspectionsReflect 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