Managing%20the%20Notification%20Process

1
Managing the Notification Process

• Workshop on the
• Integrity Management Rule for
• Large Liquid Pipelines
• Beth Callsen
• August 7, 2001

2
OPS Posture

• Flexibility for Credible, Evolving, Innovative
  Programs
• Enforcement for Non-responsiveness
• The Notification Process is not a Remedy for Bad
  Planning

3
Types of Notifications

• Intent to Use Other Assessment Technologies
• Inability to Meet Required Repair Schedule
• Plan to Reassess Pipe Segment(s) Less Frequently
  than Every Five Years

4
Guiding Principles

• OPS Will Review all Notifications and Respond (in
  a timely way) if They are Unsatisfactory
• Notifications will be Subject to Factual Review
  During OPS Inspections
• The Public will have Internet Access to Company
  Notifications and OPS Responses

5
Guiding Principles, continued

• Submitting a Notification does not Eliminate
  Safety Related Condition Reporting Requirements
• OPS will Provide Guidance on Minimum Information
  Needed to Facilitate a Response

6
As it Reviews NotificationsOPS will Consider

• Operator Performance History
• Practical Issues (Weather, Permitting
  Difficulties)

7
OPS Processing of Notifications

• Managed out of OPS Headquarters
• Involvement by Affected Regions
• Notifications will Likely Lead to Enforcement
  Action Possible if Late, Incomplete or
  Technically Inadequate