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This program update focuses on optimizing inspection efficiency and refining protocols to enhance pipeline safety. Changes include consolidation of process formality areas, reduction in the number of questions in certain protocol areas, and emphasis on periodic evaluations as pipelines progress past baseline assessments. Areas of future inspection emphasis include the development of systematic evaluation processes for preventive and mitigative measures, training for personnel reviewing assessment results, and updates to risk analysis procedures. Additional focus areas include enhancing HCA protection measures, ensuring comprehensive risk analysis, and providing technical justifications for pipe integrity issues. Field verification inspections will target areas such as HCA zones, ILI actions, repair activities, and implementation of preventive measures according to region-specific criteria.
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Inspection Program Improvements Peter Katchmar OPS Western Region May 17, 2005
Inspection Protocol Updates • Protocols re-examined for content and organization as part of inspection continuous improvement • Changes focused on optimizing inspection efficiency and eliminating redundancy • Updated protocols posted on IIM (http://primis.phmsa.dot.gov/iim/index.htm) • Cross-reference document posted on IIM
Protocol Update Highlights • Process formality and revision control areas consolidated into new protocols 8.05 and 8.06 • Most protocol areas reduced in number of questions • For example, Segment Identification (Protocol area 1) now has eight questions vs. previous twelve
Protocol Update Highlights • No changes to Remedial Action area (Protocol area 4) • Transferred “Installed Leak Detection System Information” protocol (6.05) to Operator Performance Data information sheet
Protocol Update Highlights • Periodic Evaluations split out from “Periodic Evaluation and Assessment Intervals” (Protocol 7.01) • Reflects importance of 195.452(j)(2) as IMPs progress past baseline assessments • Rule requires frequency of periodic evaluations based on risk factors specific to the pipeline
Protocol Update Highlights • 195.452(j)(2) contains a specific set of minimum information that periodic evaluations must consider • Assessment results (baseline and periodic) • Information/risk analysis • Remediation decisions • Preventive and mitigative actions decisions
Areas of Emphasis in Future Inspections • Previously identified “opportunities for improvement” from past inspections • “Most Common” areas of identified issues • Previously discussed for each area • Overall “most common” list of issues
Overall Most Common Issues Areas • Developing and implementing a systematic, documented process to evaluate additional preventive and mitigative measures to protect HCAs • Consideration of facilities (e.g., tanks) in risk analysis
Overall Most Common Issues Areas • Development of a process to adequately train personnel responsible for reviewing assessment results • Integration of other pertinent data in a timely manner when evaluating assessment results
Overall Most Common Issues Areas • Use of local knowledge, field personnel input, and other sources to update HCA information • Development of a comprehensive risk analysis process that considers all required risk factors • Inclusion of adequate detail in all areas of the integrity management plan
Overall Most Common Issues Areas • Technical justification for pre-70 LF ERW or lap-welded pipe not being susceptible to seam integrity issues • Development of a documented EFRD needs analysis
Overall Most Common Issues Areas • Documentation of the reasons for changes to the Baseline Assessment Plan • Development of ILI vendor specifications, including tool tolerance requirements and timeframes for completion of ILI reports
Field Verification Inspections • Regions interested in verifying IM-related field activities. Examples: • HCA areas of interest • ILI actions • Repair and remediation activities • Installation or implementation of preventive and mitigative measures • Region-specific criteria for activities selected