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Integrity Management Inspection Process Don Moore, OPS Central Region
Integrity Management
Inspection Process
Don Moore, OPS Central Region
Office of Pipeline Safety
What Approach Did OPS Take?
• Communicate with Industry/Stakeholders
• Develop Detailed Inspection Protocols
• Training of Inspectors
• Consistently Apply Inspection Process
• Development of Enforcement Approach
Office of Pipeline Safety
Implementing IM Website
• http://primis.phmsa.dot.gov/iim– Rule and Federal Register Notices– FAQs (linked to sections of the rule)– Inspection Protocols– Fact Sheets and Other References– Public Meeting Presentation Material– Online Notification Submittal and Status– Opportunity to Submit Comments to
OPS
Office of Pipeline Safety
Frequently Asked Questions
• Clarify rule requirements– Carefully Reviewed to Ensure
Consistency with Intent of Rule• Provide information on inspection
program• Communicate OPS Expectations• Opportunity for Public Input• Can be sorted to identify recent
updates
Office of Pipeline Safety
Public Workshops
• August 2001 - Houston– Rule Requirements– NPMS and the Identification of HCAs– API-1160– Segment Identification Expectations
• July 2002 – Houston– Segment Identification Inspection Results– Comprehensive Protocol Review– FAQs– Enforcement Approach
Office of Pipeline Safety
Inspection Protocol Development
• Experience from Risk Management and SII Programs
• Insights from Part 195 Inspection Experience, Conducting System Type Inspections, and Accident Investigations
• Information Obtained from “Completeness Check” Portion of Segment Identification Inspections
Office of Pipeline Safety
Inspection Protocol Development, continued
• Input from IM Inspector Working Meetings
• Guidance from Subject Matter Experts• Protocol Effectiveness Reviews at
Periodic Lessons Learned Meetings
Office of Pipeline Safety
Protocol Content• Organized by Program Elements in 452
(f), Protocols contain questions to:– Evaluate IM Process and Methods– Review Process Implementation – Evaluate Operator Understanding of
Integrity Issues and Actions Taken to Protect HCAs
• Guidance for each question identifies:– Prescriptive requirements– Characteristics of an effective program
Office of Pipeline Safety
Inspector Training• Classroom Training: Specific courses
on the following specialized subjects:– Rule Requirements– Inspection Protocols – Management Systems and Risk Analysis– Pipeline Materials and Defects– Welding Technology– In-Line Inspection– Corrosion Control– SCADA and Leak Detection
• Mentoring program for new inspectors
Office of Pipeline Safety
Inspection Process• Pre-Inspection Information Gathering • Inspection Duration 1 – 2 weeks,
depending on:– Size and complexity of pipeline
system(s)– HCA exposure– Number of assessments
completed– Complexity of program processes
and completeness of documentation
• Operator IM Program Presentation
Office of Pipeline Safety
Inspection Process, continued
• Protocol Guided Inspection– Protocols support an investigative,
analytical review – are not a checklist– Process and Documentation
• Operator understanding of process– Implementation and Records
• Operator understanding of significant integrity threats and how they are being managed
• Exit interview• Documentation
– Summary Report
Office of Pipeline Safety
Inspection Participants
• Government– Interstate pipeline
• OPS (multi-Region teams for large operators)
• Interstate agents, if applicable– Intrastate pipeline
• OPS or State program
Office of Pipeline Safety
Inspection Participants
• Operator– IM Program Manager – Individuals Involved in IM
Program:• Operations• Maintenance• Risk Assessment • Assessment Results Evaluation• Corrosion Control • Leak Detection
– Outside consultants, if used
Office of Pipeline Safety
Documentation Reviewed During Inspection
• IM Program Description, latest revision
• Baseline Assessment Plan• O&M Manual• Procedures, Guidelines, and
Technical Reports referenced by the IM Program description
Office of Pipeline Safety
IM Program Records Reviewed During Inspection
• Assessment Results– Preliminary and Final ILI Vendor Reports– Operator evaluation of ILI Results
including the Integration of other Data and Information
– Hydrostatic Test Reports • Results of ILI Tool Data Evaluation
– Date of Discovery– Anomaly characterization and
categorization
Office of Pipeline Safety
IM Program Records Reviewed During Inspection, continued
• Repair Records– Date of repair– Location of Repair– Type of Repair
• Pressure Reduction Records – Immediate repair conditions– 60 and 180 day anomalies for which
remediation can not be accomplished in required time
Office of Pipeline Safety
Inspection Process Improvements
– Inspector Lessons Learned Meetings •Common industry problems, inspection experiences, and unique insights
•Effectiveness of Protocols•Areas where additional guidance is needed
–New or improved FAQs–Areas where technical expertise should be brought in
Office of Pipeline Safety
Enforcement Objectives for IM
•Assure operators are developing and implementing IM Programs consistent with the rule:– Performing integrity assessments in
accordance Assessment Plans– Addressing issues discovered through
assessments– Developing and implement required IM
program elements to provide improved protection for HCAs
•Foster improvements in IM Programs as they proceed from a “Framework” to a mature program
Office of Pipeline Safety
OPS Enforcement Approach
• Enforcement Instruments the Same as for Standard Inspections– Notice of Amendment (NOA)– Warning Letter– Notice of Probable Violation (NOPV)
•Proposed Compliance Order•Proposed Civil Penalty
– Corrective Action Order• Feedback also provided through Exit
Interviews, Inspection Summary Reports, and Letters of Concern
Office of Pipeline Safety
Enforcement for Prescriptive Requirements
• Rule has clearly required actions and time frames– Segment Identification– Baseline Assessment Plan and Framework
Preparation – Baseline Assessment Methods & Schedules– Mitigation/Repair Time Frames– Re-assessment Intervals
• NOPV and Warning Letter used to address probable violations
Office of Pipeline Safety
Enforcement for Process-based Requirements
• Process-based Requirements Involve Development of IM Programs– In-Line Inspection Results Review and Data
Integration– Risk Analysis
• Variety of Acceptable Processes• Rule allowed for a “framework” maturing
into a fully developed program• These characteristics dictated a different
approach for enforcement
Office of Pipeline Safety
Guiding Principles for Process-based Requirement
Enforcement• Foster Development of Mature and
Effective IM Programs, Processes & Tools
• No Rigid “Standard” for IM Program Acceptance
• Structured Inspection Protocols Focus on Basic Requirements & Visible, Demonstrable Efforts to Comply
• Strive for Consensus among inspection teams
Office of Pipeline Safety
Process-based Requirement Enforcement
• Extensive use of NOAs & Letters of Concern
• NOPVs restricted to:– where little or no evidence of process
development was presented, – omission of rule requirements for
program elements (e.g., required risk factors, ignoring available data), or
– technical errors and unjustified assumptions resulting in:
• Inadequate understanding of risk conditions; or
• Potential for significant impact on the level of protection provided to HCAs.
Office of Pipeline Safety
Enforcement Approach is Still Evolving
• Revised our approach to close NOAs based on experience from Segment Identification Inspections– Eliminated requirement for “order
directing procedure amendments”
• Continuing to reengineer our internal processes to process cases faster– Developing detailed guidance for IM
enforcement decisions that will expedite actions recommended by the Region inspection teams
Office of Pipeline Safety
• Re-establish Enforcement Program’s long term goals and objectives– Logically structuring regulatory
strategies to achieve goals– Defining and implementing actions
to achieve strategies– Creating metrics to evaluate
enforcement program effectiveness
Enforcement Approach is Still Evolving, continued
Office of Pipeline Safety
Summary – The Path We’ve Taken
• Extensive Industry/Stakeholder Communication
• Detailed Inspection Protocols• Broad-based Inspector Training in New
Areas• Internal Efforts to Assure Consistency
in the Inspection Process• Evolving Enforcement Approach
Next Up –What we learned on our Journey
