Integrity Management Rule Overview

1
Lessons Learned from Integrity Management
Inspections
Byron Coy OPS Eastern RegionDerick 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 are generally able to meet repair
  deadlines

3
Summary of Experience to Date

• 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

4
OPS Perspective on Inspection Process

• OPS successfully implemented a programmatic
  inspection approach (vs. yes/no checklist)
• Measures to achieve consistency in identifying
  issues have been effective

5
OPS Perspective on Inspection Process

• 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

6
OPS Perspective on Inspection Process

• Operator interactions have been generally
  cooperative with open communication
• OPS provided operators with significant and
  well-received feedback on areas for improvement

7
OPS Perspective on Inspection Process

• Enforcement approach strives to promote operator
  program development and ongoing improvement
• Inspection approach continues to improve

8
General Inspection Observations

• 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
• Operator is still ultimately responsible

9
General Inspection Observations

• Program quality correlates better to corporate
  resources than pipeline mileage

10
IM Plan Organization

• Experience
• Everything from outlines to multi-volume
  documents
• Evidence of compliance for completion sometimes
  missing

• Expectations

11
IM Plan Organization

• Expectations
• Do not regurgitate the rule
• 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

• Experience
• Everything from outlines to multi-volume
  documents
• Evidence of compliance for completion sometimes
  missing

12
Segment Identification

• Experience
• Buffer zones of several sizes
• Some weak technical justifications
• Overland spill transport models
• Simplifying assumptions for water transport

• Expectations

13
Segment Identification

• Experience
• Buffer zones of several sizes
• Some weak technical justifications
• Overland spill transport models
• Simplifying assumptions for water transport

• Expectations
• Technical justification is important
• Elaborate approaches are not always necessary
• Use of field knowledge to capture all HCAs
• May not need major re-review

14
Baseline Assessment Plan

• Experience
• 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

• Expectations

15
Baseline Assessment Plan

• Experience
• 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

• Expectations
• Spreadsheet or table can suffice as the plan
• 50 and 100 mileage requirements must be
  satisfied
• Prioritization method can match complexity and
  risk of system used to establish a schedule

16
Integrity Assessment Results Review

• Experience
• Broad spectrum of approaches GIS-based
  analytical tools to nothing at all
• Data integration varies from computer based to
  informal process to none

• Expectations

17
Integrity Assessment Results Review

• Experience
• Broad spectrum of approaches GIS-based
  analytical tools to nothing at all
• Data integration varies from computer based to
  informal process to none

• Expectations
• Thorough review of vendor ILI reports by operator
  personnel
• Involve the experience/ expertise in the company
• Integration with non-ILI data
• Document cause of hydrotest failures

18
Discovery

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

• Expectations

19
Discovery

• Experience
• Timely vendor reporting can be a problem
• Some lengthy times between deformation and metal
  loss tools
• 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
• Act on data from single tool if sufficient for
  discovery and 2nd tool delayed
• Document why discovery extends beyond 180 days
  after assessment

20
Repair and Remediation

• Experience
• Operators understand and are trying to meet
  repair deadlines
• Rules repair provisions not always in OM
  procedures
• Some notifications when schedule can not be met
  and pressure not reduced

• Expectations

21
Repair and Remediation

• Experience
• Operators understand and are trying to meet
  repair deadlines
• Rules repair provisions not always in OM
  procedures
• Some notifications when schedule can not be met
  and pressure not reduced

• Expectations
• Records should clearly show assessment,
  discovery, and repair dates
• Feedback to ILI analyst of actual excavated
  defect conditions and repair information

22
Information/Risk Analysis

• Experience
• Complicated mathematical models to SME approaches
• Simple approaches for prioritizing segments more
  detailed methods for looking at segment-specific
  threats
• Justification for assumptions lacking

• Expectations

23
Information/Risk Analysis

• Experience
• Complicated mathematical models to SME approaches
• Simple approaches for prioritizing segments more
  detailed methods for looking at segment-specific
  threats
• Justification for assumptions lacking

• Expectations
• Systematic process
• Comprehensive consideration of threats
• Inclusion of facilities
• Involvement of all relevant operator
  expertise/experience
• Investigative approach

24
Preventive Mitigative Measures

• Experience
• Few operators had mature process for this element
• Processes often not well developed or documented
• Have seen few leak detection and EFRD evaluations

• Expectations

25
Preventive Mitigative Measures

• Experience
• Few operators had mature process for this element
• Processes often not well developed or documented
• Have seen few leak detection and EFRD evaluations
  

• Expectations
• Consideration of potential preventive and
  mitigative actions not assumption that existing
  programs are enough
• Documented, risk-based justification
• Leak Detection / EFRD analysis to be in place

26
Continual Evaluation and Assessment

• Experience
• Few operators considered periodic evaluations
• Tendency to default to a 5 year assessment
  interval

• Expectations

27
Continual Evaluation and Assessment

• Experience
• Few operators considered periodic evaluations
• Tendency to default to a 5 year assessment
  interval

• Expectations
• Baseline Plan transitions into an on-going
  assessment plan
• For some lines assessment more frequently than 5
  years is appropriate

28
Continual Evaluation and Assessment

• Experience
• Wide variation in how continuing evaluation is
  approached
• Some interval extension notifications received by
  OPS

• Expectations

29
Continual Evaluation and Assessment

• Experience
• Wide variation in how continuing evaluation is
  approached
• Some interval extension notifications received by
  OPS

• Expectations
• Available techniques for corrosion growth
  modeling, fatigue crack growth models may be
  useful
• Sound basis for treatment of seam integrity
  susceptibility, SCC

30
IM Program Effectiveness

• Experience
• Little attention given to this element
• Performance measures have mostly been those in
  API-1160 sometimes less
• Some good approaches to root cause analysis

• Expectations

31
IM Program Effectiveness

• Experience
• Little attention given to this element
• Performance measures have mostly been those in
  API-1160 sometimes less
• Some good approaches to root cause analysis

• Expectations
• Process in place by which the operator reviews
  its program effectiveness (e.g., internal and
  external audits, management reviews)
• Management awareness and support

32
Common IM Program Issues
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Segment Identification Issues
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Segment Identification Issues
35
Baseline Assessment Plan Issues
36
Baseline Assessment Plan Issues
37
Baseline Assessment Plan Issues
38
Assessment Results Issues
39
Assessment Results Issues
40
Assessment Results Issues
41
Remedial Action Issues
42
Remedial Action Issues
43
Remedial Action Issues
44
Information/Risk Analysis Issues
45
Information/Risk Analysis Issues
46
Preventive Mitigative Issues
47
Preventive Mitigative Issues
48
Continual Assessment/Evaluation Issues
49
Continual Assessment/Evaluation Issues
50
Continual Assessment/Evaluation Issues
51
Program Evaluation Issues
52
Program Evaluation Issues
53
Notification Experience

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

54
Notification Experience
Notifications by Type
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Notification Experience
16 of the notifications for intrastate pipelines
involved pipelines in Texas
Notifications by Pipeline Category
56
Notification Experience
Notifications by Disposition
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Notification Experience
A total of 26 operators have submitted
notifications
Notifications by Operator
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Notification Experience

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

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The End