Enhancing Segment Identification Protocol for Pipeline Integrity Management

1. Segment Identification Protocol Review Zach Barrett – Western Region Integrity Management Workshop July 23-24, 2002

2. Program Element Requirements §195.452 (f) (1) requires each operator to include, at minimum, the following element in its written integrity management program: A process for identifying which pipeline segments could affect a high consequence area.

3. Why is OPS reviewing Segment Identification Again? • Many operators plan improved approaches • Follow-up on enforcement issues from Segment Identification inspections • Changes in operator assets • Changes in HCAs • Both for NPMS and operator identified • More extensive verification is necessary

4. Segment Identification Verify the Process to identify segments is: • Documented and readily understood • Adequate and conservative • Identifies segments by definable beginning and endpoints • Documents methods and assumptions

5. Segment Identification Verify the Process to identify segments: • Includes provisions for record retention • Identifies roles and responsibilities • Provides for quality assurance reviews/audits • Includes explanation of software

6. Segment Identification Does the SI Process have steps for identifying, documenting, and maintaining up-to-date geographic locations and boundaries of HCAs Utilizing: • NPMS – Updated June 1, 2002 • No - New York (Drinking Water) • No - Pennsylvania (Ecological) • Other Sources – Local knowledge • Water authorities • State heritage organizations • Permitting records • Oil Pollution Act Response Plans

7. Segment Identification Does the SI Process for identifying, documenting, and maintaining up-to-date geographic locations and boundaries of HCAs include: • Verification of HCA boundary information • Periodic review for new or changing HCAs • Integrate with field activities – ROW patrols, CP surveys, and maintenance

8. Segment Identification Verify the SI Process includes controls for revisions made to the SI analysis: • Review and approval of revisions • Changes to be adequately validated, justified and documented • Provides for interface with other program elements • Risk Analysis & Mitigation Measures • Spill Response & Emergency Plans

9. Segment Identification Is the SI Process adequate for determining locations where a pipeline facility is physically located within an HCA: • Identification of individual segment beginning and end points • Include terminals and other facilities • Validate SI analysis technique/software capability

10. Segment Identification If making a case that segments physically located in a HCA could not affect the HCA: • Must be based on a documented valid and conservative technical analysis • Minimal or no impact must be demonstrated • HVL properties • Topography • HCA characteristics

11. Segment Identification Does the SI Process include technically adequate and conservative methods for considering projected release points along the pipeline including: • Water crossings and drainage pathways • Consideration of release points closest to HCAs • Worst case topography • Adequacy of standard spacing of projected release points to be analyzed

12. Segment Identification Does the SI Process contain conservative assumptions for projecting release volumes and/or rates for consequence and transport analysis considering: • Size of integrity breach and operating conditions • For releases above and below SCADA detection • Leak detection and response times • For releases above and below SCADA detection • Consider release at night for local detection • Drain down • Sensitivity analysis • History of response times and release volumes

13. Segment Identification Does the SI Process provide for an overland flow analysis to determine the extent of commodity spread and its effects on HCAs? • Valid and conservative assumptions for: • Consideration of Topography • Release volume, pool thickness, soil permeability • Local features (sewers, farm tile, drains) • Validation of software

14. Segment Identification Does the SI Process include an analysis of water transport to determine the extent of commodity spread and its effects on HCAs? • Valid and conservative assumptions for: • Analysis methodology and techniques • Consideration of Indirect introduction into water (overland, spray, etc.) • Individual stream conditions and water properties • Spill identification and response time • Affects on commodity properties in water • MTBE – Methyl Tertiary Butyl Ether

15. Segment Identification Does the SI Process include an analysis of air dispersion of vapors to determine the extent of harmful commodity vapor spread and its effects on HCAs? • Valid and conservative assumptions for: • Analysis model and software inputs • Commodity physical properties • Flammability and toxic hazards • Threshold level of concern (concentration)

16. Segment Identification If SI Process utilizes a buffer zone substantiate its conservativeness considering: • Worst-case overland, water and air transport distances • Utilized methodology and techniques • Release history • Facilities and terminals • If software generated buffer, must demonstrate validation

17. Information Collection • Updated pipeline system mileage • Miles of pipeline that could affect HCAs • Verify and update mileage breakdown: • Direct intersects • Outside HCA but could affect • Type of HCA affected • State • Commodity transported • Interstate/intrastate • Low stress

18. Expectations • Operators Should be Aware of Changes to HCAs • Improved Segment Identification Methods and Results • Segment Identification Results are to be Integrated with Other Program Elements