Integrity Management Lessons Learned

1. Integrity Management Lessons Learned Louisiana Pipeline Safety Seminar August 2003

2. Presentation Format • Identify Inspection of Program Element Requirements • Regulator Expectations • Experience to Date with Large Interstate Operators

3. Inspect Basic IM Program Requirements • Baseline Assessment Plan • Framework for Implementing IM Program Elements • Implement and Follow the IM Program

4. Experience Everything from outlines to multi-volume documents Evidence of compliance for completion sometimes missing Expectations Don’t regurgitate the rule Not all processes have to be fully documented Process should support the implementation of a more consistent and thorough approach General IM Framework

5. Inspect IM Program Elements • Identifying Segments that Could Impact HCAs • Baseline Assessment Plan • Reviewing Assessment Results by Qualified Personnel • Making Mitigation and Repair Decisions

6. Highest Risk H M Consequences Lowest Risk L LMH Likelihood of Occurrence IM Program Elements • Integrating and Analyzing Risk Information • Identifying Additional Preventive and Mitigative Actions • Ongoing evaluation and assessment of pipe integrity • Measuring Program Performance

7. Experience Buffer zones of all sizes Some weak technical justifications Spill transport models Simplifying assumptions for water transport Expectations Elaborate approaches are not necessary Technical justification is important For lines largely within HCAs, it may be more practical to consider the entire system as “could affect” Segment Identification

8. Experience Most Plans satisfactory, but some fail to include basic requirements – e.g., dates, assessment method, justification For ILI, Plans are structured around piggable sections – some challenges to correlate with “could affect” segments Expectations Spreadsheet or table can suffice as the plan Demonstrate that the 50% mileage requirement is satisfied Rigorous prioritization method is not necessary to establish a schedule Baseline Assessment Plan

9. 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 Evidence of Analysis of vendor ILI reports Involve the experience/expertise in the company Document cause of hydrotest failures Integrity Assessment Results Review

10. Experience Timely vendor reporting is a problem, but not universal Some lengthy times between deformation and metal loss tools Operators build in time to confirm defects are “real” (e.g., not repaired) Expectations Expect operators to promptly reduce pressure for immediate repair conditions Document why discovery extends beyond 180 days after assessment “Discovery”

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

12. 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 Involvement of all relevant operator expertise/experience Investigative approach Information Analysis

13. Experience Few operators have progressed to this stage Processes are not well developed or documented Have seen few leak detection and EFRD evaluations Expectations Serious consideration of potential preventive and mitigative actions – not just assumption that existing programs are enough Documented, risk-based justification Preventive & Mitigative Measures

14. Experience Few operators have considered this program element in detail Tendency to default to a 5 year interval No one has sent in a notification asking for a longer period yet Expectations Baseline Plan transitions into an on-going assessment plan For some lines assessment more frequently than 5 years is appropriate Available techniques for corrosion growth modeling, fatigue crack growth models may be useful Continuing Evaluation and Assessment

15. 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 by which the operator reviews its program effectiveness (e.g., internal and external audits, management reviews) Management awareness and support IM Program Effectiveness

16. Summary of Experience to Date • Operators Generally Understand and are Implementing the Assessment Provisions of the Rule • Progress is Needed in Development of IM Program Elements • OPS is Continues to Refine its Inspection Process • The Objective is Improved Performance Results from a Commitment to Continuous Improvement – Both OPS and Industry