OPS IMP Inspection Process

1
OPS IMP Inspection Process

• Workshop on the
• Integrity Management Rule for
• Large Liquid Pipelines
• Paul Wood
• August 7, 2001

2
OPS Process Implemented in Stages

• Initial Review Focused on Presence of Framework
  Containing All Program Elements
• Appropriate Decision Processes
• Reasonable Plan for Improvement
• Success in Initial Review will not Imply
  Long-Term Acceptabilityof Operators Process

3
OPS Process Implemented in Stages, cont.

• Subsequent Reviews will Examine Operator
  Performance against Roadmap in Framework
• Will Examine Improvements in the Process

4
Comprehensive Review of Baseline Assessment Plan
IM Framework Objectives

• Inspect for Compliance with Requirements of
  Baseline Assessment Plan and IM Framework
• Promote Continuous Improvement

5
Features of Inspection Process

• Focused at Company Level (Not Region-by-Region)
• Separate from Normal Compliance Inspections
• Multi-Discipline, Multi-Region Teams will Conduct
  Inspections
• Reasonable Team Size Requires Focused State
  Participation

6
Inspection Process Issues

• Evaluation Basis Consistency
• The Inspection Process Itself
• Team Composition Expertise
• Nature of Feedback to Operators
• Schedule
• Enforcement (Addressed Later by Chris Hoidal)

7
Evaluation Basis Consistency

• Criteria being Developed to Guide Evaluation of
  Performance-Based Aspects
• Examine Operator Data Collection Analysis
  Process
• Examine Operator Analytical Processes
• Examine Effectiveness of Operator Processes
• Criteria will Evolve with Time Allow Some
  Implementation Flexibility
• Quality Documentation of Inspection Results is
  Essential to Support Follow-up Inspections.

8
Inspector Expertise

• Pipeline Design Operations
• Assessment/Inspection Technology
• Management Systems Processes
• Risk Analysis Methods

9
Type of OPS Feedback to Operators

• Direct Operator to Modify Program to Address
  Clear Deficiencies
• Identify Aspects of Process or Tools to Consider
  Modifying
• Encourage Operator to Consider Adopting
  Noteworthy Practices
• Promote Consideration of Use of Demonstrated New
  Technologies

10
OPS Inspection of Operator IM Program
Implementation

• Confirmation of Integrity Assessments
• Confirmation of Repairs
• Review of Notifications
• Review of Assessment Results and Integration with
  Other Data
• Review Basis for Repair Method Selection and
  Schedule

11
OPS Inspection of Operator IM Program
Implementation, Cont.

• Review Operator Risk Analysis and Determination
  of Need for Additional Risk Controls (e.g., EFRDs
  and leak detection enhancements)
• Review Basis for Re-assessment Method Selection
  and Schedule
• IM Program Development
• Operators Internal Performance Evaluation

12
Separate vs Integrated Inspection

• Some Aspects could be Integrated with Standard
  Inspections
• Other Aspects may be Better Performed in
  Separate, In-depth Inspections
• Expect Evolution from Entirely Separate
  Inspections to Largely Integrated with Standard
  Inspections

13
Scheduling On-going IM Program Implementation
Inspections

• Base Frequency on Results of Inspection of
  Comprehensive Plan and Framework
• Program Maturity and Quality
• Operator Performance
• Progress in Implementing Assessment Plan
• May Involve Multiple Company Locations
• Complete One Round of IM Program Implementation
  Inspections by 9/30/04 (for large liquid
  operators)