Charlie Childs Pipeline Integrity Consultant

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Charlie ChildsPipeline Integrity Consultant

• SGA Web Conference Session 6 Audit Feedback
  from PHMSA
• April 28, 2008

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El Paso Corporation
the place to workthe neighbor to havethe
company to own
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Asset Map
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EPPG IMP Audit Experience Agenda

• Timeline
• How Audit worked
• PHMSA Expectations
• What went well and not so well
• Benefits of the Audit
• Recommendations

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Audit Timeline

• February 2006 - Pre-meeting
• April May 2006 Audit (3 weeks)
• August 2006 Meeting to discuss one specific
  issue
• March 2007 Request for information and we
  provided updates to processes
• July 2007 Proposed enforcement actions received
  from PHMSA
• April 2008 Hearing
• ?? Date for 2nd Hearing

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How Audit worked

• Protocol sections scheduled before hand
• Operator presentation overview, before each
  major section
• PHMSA followed Protocols
• Covered processes
• Vertical slice
• PHMSA Caucuses
• Exit issues each week
• What you know at the end of the audit
• Have an idea of the issues that were raised
• Not know what issues are enforcement items
• Not know if you answered all the issues raised
  during the audit some you will, some you wont

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PHMSA Expectations

• Documentation, documentation, documentation
• Processes, processes, processes detailed
• Individual inspectors will have their areas of
  expertise and interest
• Knowledgeable individuals

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What went well and not so well

• What went well
• Pre-audit preparation
• Business like approach by both EPPG and PHMSA
• Good rapport during the audit
• PHMSA listened to our explanations and worked
  hard to understand our program
• Time was well managed
• What did not go as well
• Long period of waiting in post audit process and
  little communication during this time
• Not know what issues are enforcement items
• Audit issues are written in generic protocol
  language not written to describe the specific
  issue discussed in the audit

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Benefits of the Audit

• Preparation for audit improved processes and
  emphasized importance of IMP
• Improvement to IMP Processes identified during
  Audit
• Thorough audit
• Good feedback on importance of solid and detailed
  documentation of day to day OM activities

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Recommendations

• Before Audit
• Tie your manual to the protocol sections
• Know the protocols, FAQs, and your processes
• Take time to complete a thorough pre-inspection
  form
• Practice/Mock audit
• Attitude - open to improvement, ready to listen
• Management participation and support

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Recommendations

• Clear and thorough presentation of your program
  overview and for each protocol
• Involve SMEs
• You will have disagreements
• Justify your procedures technically and based on
  the regulations
• Stay open for improvement
• Stand up for what is right in the right way,
  including if PHMSA is working outside the
  regulations

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Charlie ChildsPipeline Integrity Consultant

• SGA Web Conference Session 6 Audit Feedback
  from PHMSA
• April 28, 2008