Current Inspection Process Current Inspection Process for Operators offor Operators of

Hazardous Liquids Hazardous Liquids PipelinesPipelines

Rod SeeleyRod SeeleyOPS SW Region DirectorOPS SW Region Director

May 18, 2005May 18, 2005

22

Goals of Future IMP InspectionsGoals of Future IMP Inspections

Continuous improvement in OPS IMP Continuous improvement in OPS IMP inspection processinspection process

Seamless inspection process to Seamless inspection process to OperatorsOperators

33

OPS Liquid IMP Inspection OPS Liquid IMP Inspection Organizational ChangesOrganizational Changes

Management of IM inspection Management of IM inspection program has shifted from OPS program has shifted from OPS Program Development to OPS Program Development to OPS RegionsRegions

OPS Program Development will OPS Program Development will monitor the inspection process and monitor the inspection process and identify significant trendsidentify significant trends

44

Seamless Transition in Seamless Transition in Inspection ProcessInspection Process

OPS SW Region to lead Liquid IMP OPS SW Region to lead Liquid IMP inspections of many large Operators with inspections of many large Operators with jurisdictional assets in multiple Regionsjurisdictional assets in multiple Regions

Change should be seamless to OperatorsChange should be seamless to Operators All OPS Regions participating in and/or All OPS Regions participating in and/or

directly supporting SW Region-lead directly supporting SW Region-lead inspections for large multi-region inspections for large multi-region OperatorsOperators

55

Inspection ProcessInspection Process

Inspection process is the same for all Inspection process is the same for all Operators and follows the format Operators and follows the format used in first round of IMP inspectionsused in first round of IMP inspections Pre-inspection meeting or Pre-inspection meeting or

teleconferenceteleconference Inspection (approximately two weeks)Inspection (approximately two weeks) Exit interview at conclusion of inspectionExit interview at conclusion of inspection

66

Continuous Improvement in Continuous Improvement in OPS IMP Inspection ProcessOPS IMP Inspection Process

Implemented systematic processes Implemented systematic processes for the conduct of IMP inspectionsfor the conduct of IMP inspections

Revised inspection protocols and Revised inspection protocols and Inspector guidance materialsInspector guidance materials

Utilizing previous inspection results Utilizing previous inspection results in preparation for IMP inspections in preparation for IMP inspections

Current Inspection Process Current Inspection Process for Operators offor Operators of

Hazardous Liquids Hazardous Liquids PipelinesPipelines

Chris McLarenChris McLaren

OPS SW RegionOPS SW Region

May 18, 2005May 18, 2005

88

Talking PointsTalking Points

Lessons learnedLessons learned IMP inspection formatIMP inspection format Areas of improvementAreas of improvement Consensus standardsConsensus standards Path forwardPath forward

99

Operators generally understand and Operators generally understand and are implementing the assessment are implementing the assessment provisions of the ruleprovisions of the rule

Progress is needed in development Progress is needed in development and implementation of several IMP and implementation of several IMP elementselements Preventive & mitigativePreventive & mitigative Leak detection and EFRD analysesLeak detection and EFRD analyses Periodic evaluationsPeriodic evaluations Re-assessment interval determinationRe-assessment interval determination Program evaluationProgram evaluation

Lessons Learned from First Round Lessons Learned from First Round IM InspectionsIM Inspections

1010

Improved performance results from a Improved performance results from a commitment to continuous improvementcommitment to continuous improvement

Operator interactions have been Operator interactions have been generally cooperative with open generally cooperative with open communicationcommunication

Inspection approach continues to Inspection approach continues to improve with the use of protocol driven improve with the use of protocol driven inspectionsinspections

Lessons Learned from First Round Lessons Learned from First Round IM InspectionsIM Inspections

1111

All OPS Regions participating in and All OPS Regions participating in and supporting SW Region-lead supporting SW Region-lead inspections for large multi-region inspections for large multi-region OperatorsOperators

IMP related field activities and Region-IMP related field activities and Region-specific issues identified during status specific issues identified during status update meetings and IM inspections update meetings and IM inspections for follow-up by individual Regionsfor follow-up by individual Regions

OPS Organizational ChangesOPS Organizational Changes

1212

IMP status update meetingsIMP status update meetings Scheduling of inspectionsScheduling of inspections Performance of inspections using Performance of inspections using

revised inspection protocolsrevised inspection protocols Documentation requirementsDocumentation requirements Reporting requirementsReporting requirements

2005 Inspection Format2005 Inspection Format

1313

IMP Status Update Meetings IMP Status Update Meetings conducted at SW Region with nine conducted at SW Region with nine large liquid multi-region Operators large liquid multi-region Operators being inspected by the SW Region in being inspected by the SW Region in 20052005

Operator IMP improvements since Operator IMP improvements since previous inspection discussedprevious inspection discussed

OPS expectations for next inspection OPS expectations for next inspection discusseddiscussed

Performed pre-inspection activitiesPerformed pre-inspection activities

Status Update MeetingsStatus Update Meetings

1414

Provide opportunity for Operators to Provide opportunity for Operators to discuss specific concerns and areas discuss specific concerns and areas of uncertainty with OPSof uncertainty with OPS

Ensure appropriate inspection Ensure appropriate inspection resources are allocatedresources are allocated

Operator IMP-related field activities Operator IMP-related field activities identified on Regional basis to assist identified on Regional basis to assist resource allocation (e.g., witness resource allocation (e.g., witness implementation tasks – integrity implementation tasks – integrity assessments, repair and assessments, repair and rehabilitation, EFRD installation, etc.)rehabilitation, EFRD installation, etc.)

Status Update MeetingsStatus Update Meetings

1515

2005 Schedule Considerations2005 Schedule Considerations Date of previous inspectionDate of previous inspection OPS and operator personnel schedulingOPS and operator personnel scheduling Conclusion dates of any major Conclusion dates of any major

assessment/remediation programsassessment/remediation programs Timing of significant Timing of significant

mergers/acquisitionsmergers/acquisitions Anticipated closing of any relevant open Anticipated closing of any relevant open

enforcementenforcement Date of implementation of IMP-related Date of implementation of IMP-related

projects (e.g. GIS, work order systems)projects (e.g. GIS, work order systems)

Scheduling of InspectionsScheduling of Inspections

1616

Flexibility from participants was needed Flexibility from participants was needed in the inspection scheduling processin the inspection scheduling process

Future scheduling of IMP team Future scheduling of IMP team inspections to be done prior to status inspections to be done prior to status update meetings to alleviate update meetings to alleviate scheduling issuesscheduling issues

Scheduling of InspectionsScheduling of Inspections

1717

IMP needs to have matured from IMP needs to have matured from framework status into detailed process framework status into detailed process descriptionsdescriptions

All protocols will be used during All protocols will be used during inspectionsinspections

Results of the previous inspection will be Results of the previous inspection will be utilized as applicableutilized as applicable

Anticipated to take two weeksAnticipated to take two weeks

IMP InspectionIMP Inspection

1818

Use of revised protocols dated Use of revised protocols dated December 31, 2004 on OPS websiteDecember 31, 2004 on OPS website

Spreadsheets for operator Spreadsheets for operator performance data acquisition performance data acquisition revisedrevised Liquid operator program information form Liquid operator program information form

now includes leak detection systems data now includes leak detection systems data (Protocol 6.05 removed and incorporated (Protocol 6.05 removed and incorporated here)here)

IMP InspectionIMP Inspection

1919

2020

2121

Exit interview used for Exit interview used for communication to Operator of communication to Operator of strengths and weaknesses of IMP strengths and weaknesses of IMP identified during inspectionidentified during inspection

Communication to OPS Regions of Communication to OPS Regions of possible field verification activities possible field verification activities identified during the inspectionidentified during the inspection

Documentation of IMP inspectionDocumentation of IMP inspection

Post Inspection ActivitiesPost Inspection Activities

2222

Summary Report (reviewed by Operator Summary Report (reviewed by Operator for factual content prior to finalization)for factual content prior to finalization)

Electronic format of IMP is extremely Electronic format of IMP is extremely helpful in completing OPS helpful in completing OPS documentation requirementsdocumentation requirements

All documents not included in reports All documents not included in reports and/or enforcement returned or and/or enforcement returned or disposed of at conclusion of inspection disposed of at conclusion of inspection processprocess

Inspection DocumentationInspection Documentation

2323

Evaluation of leak detection Evaluation of leak detection capabilitiescapabilities

Implementation of preventive and Implementation of preventive and mitigative measuresmitigative measures

EFRD need determinationEFRD need determination Re-assessment interval determinationRe-assessment interval determination Program performance evaluationProgram performance evaluation

Areas of ImprovementAreas of Improvement

2424

Evaluation of corrosion control Evaluation of corrosion control programs and their input into risk programs and their input into risk analysis and integration with analysis and integration with integrity assessment resultsintegrity assessment results

QA/QC processesQA/QC processes Verification of data in risk analysis and use of Verification of data in risk analysis and use of

data obtained from OM&I tasksdata obtained from OM&I tasks Review of integrity assessment results and Review of integrity assessment results and

other vendor supplied dataother vendor supplied data

Areas of ImprovementAreas of Improvement

2525

StandardStandard StatusStatus CommentsComments ScheduleSchedule

ASME B31.8S – ASME B31.8S – 2001 2001 Integrity Integrity ManagementManagement

Revisions in Revisions in processprocess

Modify ECDA section Modify ECDA section and add CDA. May and add CDA. May have to wait on new have to wait on new RP0502RP0502

ASME B31QASME B31QQual. of PersonnelQual. of Personnel

Drafting StandardDrafting Standard Work started in August Work started in August - 2003- 2003

Est. completion Est. completion Q4 2005Q4 2005

NACE RP0502-2002NACE RP0502-2002Pipeline ECDAPipeline ECDA

Published 2002Published 2002 Revisions to be Revisions to be considered at NACE considered at NACE Spring MeetingSpring Meeting

Revisions in 2005Revisions in 2005

NACE RP0102-2002 NACE RP0102-2002 In-Line Inspection of In-Line Inspection of PipelinesPipelines

Updating/Updating/RevisionsRevisions

Modify to compliment Modify to compliment API 1163, TG 212 API 1163, TG 212 ReestablishedReestablished

Revisions in 2005Revisions in 2005

NACE – TG315NACE – TG315ICDA for Liquid ICDA for Liquid Petroleum PipelinesPetroleum Pipelines

Development in Development in processprocess

ICDA especially for ICDA especially for crude oil systemscrude oil systems

Draft not Draft not completed. completed. Completion date Completion date undeterminedundetermined

Industry Consensus StandardsIndustry Consensus Standards

2626

Industry Consensus StandardsIndustry Consensus Standards

StandardStandard StatusStatus CommentsComments ScheduleSchedule

NACE – RP-0204 - NACE – RP-0204 - Pipeline SSCDAPipeline SSCDA

Development in Development in processprocess

Addresses high pH and Addresses high pH and near-neutral pHnear-neutral pH

Complete in Complete in 20042004

API 1110 – Pressure API 1110 – Pressure Testing of PipelinesTesting of Pipelines

CompletedCompleted Standard on pressure Standard on pressure testing new and existing testing new and existing pipelinespipelines

CompletedCompleted

API 1163 - ILI API 1163 - ILI Systems Systems QualificationsQualifications

Development in Development in processprocess

Balloting/Public CommentBalloting/Public Comment Publish – Q2 Publish – Q2 20052005

ASNT ILI PQ – 2003 ASNT ILI PQ – 2003 ILI Personnel Qual. & ILI Personnel Qual. & Cert.Cert.

CompletedCompleted In Balloting/ Public In Balloting/ Public CommentComment

Publish – Q2 Publish – Q2 20052005

API 1162API 1162Public Public CommunicationsCommunications

Approved / In Approved / In PublicationPublication

NPRM issued Q2 for NPRM issued Q2 for inclusion in regulationsinclusion in regulations

Approved – Q3 Approved – Q3 20032003

2727

Integrity management is a continuous Integrity management is a continuous improvement regulationimprovement regulation

OPS is committed to developing and OPS is committed to developing and implementing improved tools and implementing improved tools and techniques as inspection process techniques as inspection process evolvesevolves

Operator feedback / perspective of Operator feedback / perspective of which methods are effective and which which methods are effective and which methods are not effective is important methods are not effective is important to OPSto OPS

Path ForwardPath Forward

2828

Continue to improve inspection process and Continue to improve inspection process and standardization of documentation and standardization of documentation and communication channelscommunication channels

Ensure inspections are consistently performed Ensure inspections are consistently performed and IM Rule is consistently applied during and IM Rule is consistently applied during inspection processinspection process

Field verification of IMP activitiesField verification of IMP activities Complete “second round” of IMP inspections Complete “second round” of IMP inspections

by 2007by 2007

Path ForwardPath Forward

The EndThe End