Integrity Management Inspection Process

1. Integrity ManagementInspection Process Don Moore, OPS Central Region

2. What Approach Did OPS Take? • Communicate with Industry/Stakeholders • Develop Detailed Inspection Protocols • Training of Inspectors • Consistently Apply Inspection Process • Development of Enforcement Approach

3. 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

4. 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

5. 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

6. 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

7. Inspection Protocol Development, continued • Input from IM Inspector Working Meetings • Guidance from Subject Matter Experts • Protocol Effectiveness Reviews at Periodic Lessons Learned Meetings

8. 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

9. 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

10. 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

11. 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

12. Inspection Participants • Government • Interstate pipeline • OPS (multi-Region teams for large operators) • Interstate agents, if applicable • Intrastate pipeline • OPS or State program

13. 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

14. 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

15. 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

16. 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

17. 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

18. 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 elementsto provide improved protection for HCAs • Foster improvements in IM Programs as they proceed from a “Framework” to a mature program

19. 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

20. 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

21. 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

22. 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

23. 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.

24. 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

25. Enforcement Approach is Still Evolving, continued • 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

26. 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

27. Next Up – What we learned on our Journey