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Integrity Management Rule Enforcement

Integrity Management Rule Enforcement. Integrity Management Workshop July 23-24, 2002. Enforcement Presentation Topics. Objectives OPS Enforcement Approach Prescriptive Requirements Performance-Based Requirements Segment Identification Inspection Enforcement. Objectives.

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Integrity Management Rule Enforcement

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  1. Integrity Management Rule Enforcement Integrity Management Workshop July 23-24, 2002

  2. Enforcement Presentation Topics • Objectives • OPS Enforcement Approach • Prescriptive Requirements • Performance-Based Requirements • Segment Identification Inspection Enforcement

  3. Objectives • Assure operators are developing IM Programs consistent with the rule • Performing integrity assessments • Addressing issues discovered through assessments • Developing IM program elements • Foster continuous improvement in IM Programs

  4. Tools to Achieve Objectives • FAQs and other Guidance • Feedback to Operators During Inspections • Enforcement Actions • Hearings or Other Interactions Associated with Enforcement Process • Communication of Noteworthy Practices

  5. IM Rule Enforcement • Rule has Prescriptive & Performance-based Requirements • New Challenges for Inspection and Enforcement • Drawing on Broad Organizational Experience and Expertise • Our Approach is Evolving

  6. Enforcement of Prescriptive Requirements • Prescriptive Requirements Define Clearly Required Actions & Time Frames • Segment Identification • Baseline Assessment Plan and Framework Preparation • Baseline Assessment Methods & Schedules • Mitigation/Repair Time Frames • Re-assessment Intervals

  7. Enforcement of Prescriptive Requirements, cont. • Enforcement Instruments the Same as for Standard Inspections • Warning Letter • Notice of Amendment • Notice of Probable Violation • Compliance Order • Corrective Action Order • Civil Penalties Commensurate with Severity and Safety Significance of Violation

  8. Enforcement of Performance-Based Requirements • Performance-based Requirements Involve Development of IM Programs • In-Line Inspection Results Review and Data Integration • Risk Analysis • Risk-based Decision Making (e.g., EFRDs) • There are a Variety of Acceptable Processes • OPS needs a Different Approach for such Requirements

  9. Guiding Principles for Performance-Based Requirement Enforcement • Objective: Foster Continuous Improvement of IM Programs, Processes & Tools • No Rigid “Standard” for IM Program Acceptance • Structured Inspection Protocols will Focus on Basic Requirements & Operator Efforts to Comply • Inspection Protocols Will Evolve with Time

  10. Promote Continuous Improvement • Operator Periodically Evaluates IM Program & Implements Improvements • Operator Analyzes Incident Root Causes & Implements Lessons Learned • Operator Implements New Consensus Standards • OPS Feedback & Observations from Inspections • Operator Awareness of Industry Best Practices & New Technology

  11. Example Protocol Structure • Is Process Documented? • Does Process Use All Relevant Inputs? • Is Process Logical, Technically Correct, and Adequate to Produce Desired Results? • Are Results Documented and Communicated? • Are Roles and Responsibilities Established? • Is Process Implemented as Described?

  12. Enforcement Process Evolution • Operators and OPS are Learning and will Continue to Learn • Fully Implemented and Mature Programs not Expected Immediately • “Success” in Initial Review Will Not Imply Long-term “Acceptability”of Operator’s IM Program or its Processes • Subsequent Reviews Will Examine Operator Implementation Against Plan in Framework • Will Examine IM Process Improvements & Effectiveness

  13. Feedback & Enforcement for Performance-Based Requirements • Verbal Communication During Exit Interview • Notice of Amendment to Require Changes & Improvements to IM Processes • NOPV/Compliance Orders for Non-Compliance

  14. Civil Penalties • This rule is a strong step forward in the effort to improve safety and will be enforced to assure compliance • OPS will work with companies who evidence good faith in attempting to comply • Large civil penalties can be expected for probable violations

  15. Segment Identification Inspection Enforcement • OPS Demonstrated Commitment to Enforcement of the Integrity Management Rule

  16. IM Enforcement To Date • Segment Identification Inspections • Notice of Amendment • Incomplete Technical Justification or Simplifying Assumptions that Did Not Consider all Factors • No consideration of stream transport • HVL properties not considered

  17. IM Enforcement To Date (cont.) • Segment Identification Inspections • NOPV with Proposed Civil Penalty • Did not Address Fundamental Rule Requirement • Did not identify segments that could affect USAs in states where USAs were not mapped on NPMS

  18. Summary • Committed to Firm but Fair Enforcement • Continuous Improvement of Operator Programs is Expected • Both OPS and Operators are Still Learning

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