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Segment Identification Inspections: OPS Learnings & Approach

Learn about OPS' findings, inspection approach, segment identification techniques, program development, and enforcement efforts. Discover insights on inspection results and the significance of integrity management plans.

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Segment Identification Inspections: OPS Learnings & Approach

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  1. Segment Identification InspectionsWhat did OPS Learn?

  2. Presentation Topics • Review Segment Identification Inspection Approach • Summarize Inspection Results • Segment Identification • IM Program and Baseline Assessment Plan Development • Communicate OPS Conclusions

  3. IM Inspection Approach Overview • Initial Segment Identification and Completeness Check • Comprehensive Baseline Assessment Plan and IM Framework Review • On-going Program Implementation Inspections

  4. Segment Identification and Completeness Check: Objectives • Confirm Segments Affecting HCAs have been Identified (Required by 12/31/01) • Assure Baseline Assessment Plans and IM Frameworks have Essential Elements • Identify Potential Noteworthy Practices • Support Prioritization of Comprehensive Inspections

  5. Segment Identification Inspection Approach • Inspect all Large Operators in 3 months • Inspection Duration - Approximately 1-2 Days • Multiple, Multi-Region Teams • OPS Inspectors Only • Texas RRC Inspectors Observed Several Texas Operator Inspections • Periodic Process Checks to Assure Consistency

  6. Major Components of Segment Identification Inspection • Review Operator Approach and Technical Justification for Identifying Segments • Review Small Sample of Analyses to Determine Segment Boundaries • Compare Location of Operator Segments to HCAs from NPMS • Perform Completeness Check on Baseline Assessment Plan and IM Framework

  7. Accomplishments • 40 Hazardous Liquid Operators • Operating ~ 159,000 miles of pipe • Summary Reports Prepared and (after approval) Provided to Operator to Document Inspector Feedback • Created and Implemented a Web-based Information System for Inspection Records

  8. Segment Identification Results • Percentage of Operator Mileage Identified that “Could Affect” HCAs = 39% • Median = 44% • Maximum = 100% • Minimum = 0%

  9. “Could Affect” Mileage

  10. Segment Identification:Effect of Operator Size

  11. Common Segment Identification Problems • Inadequately Justified “Buffer Zones” • Topography not Considered • Stream/Waterway Transport to HCAs not Considered • No Consideration of HVL Vapor Properties • No Consideration of HVL Impacts on USAs • No Segment Identification for Subsidiaries or Joint venture Pipelines

  12. Common Segment Identification Problems • No Segment Identification for Idle Lines • No Identification of Segments affecting USAs in States without USA Maps on NPMS (as of 12/31/01) • 50% of Operators faced this problem • Issue is likely to be corrected as most all state maps are now complete.

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

  14. Integrity Management Program Observations • Most operators Understand Rule Programmatic Requirements • Formalization of Program Needs Work • Implementing procedures and guidance • Assigned responsibilities • Documentation requirements • Many operators Plan more Technically Robust Segment Identification Determinations

  15. Baseline Assessment Plan Observations • Integrity Assessment Plans Progressing Well • Operators Strongly Prefer In-line Inspection over Pressure Testing • Operators Pigging Far More Miles than Affects HCAs. • Many are applying HCA repair criteria system-wide (though not with rule’s time constraints)

  16. Baseline Assessment Plan Observations • Weaknesses Observed in Some Operator Plans: • Basis for Segment Priorities not Readily Evident • Assessment Method Selection Criteria not documented

  17. What’s Next • Preparing for Comprehensive IM Inspections • Protocols and Guidance • Training for Federal and State Inspectors • Industry Workshop – July 23 & 24 • Inspections Begin - August 2002

  18. Segment Identification Inspection Conclusions • Operators have a Significantly Improved Understanding of Where HCAs are and Where Their Pipelines can Impact These Areas • Significant Portion of Liquid Pipelines can Impact HCAs (39%), and Even More Mileage will be Assessed as a Result of this Rule • Most Operators Understand the Importance of Developing an Integrity Management Program, but Fully Mature Programs will Take Time to Develop

  19. Segment Identification Inspection Conclusions • OPS Successfully Determined Operator Compliance with Segment Identification Requirement • Inspections began immediately after 12/31/01 deadline and were completed in 3 months • OPS Successfully Implemented a Programmatic Approach to Inspect for Operator Compliance (versus a yes/no checklist) • Measures to achieve consistency were effective • Operator Interactions were Generally Cooperative with Open Communication • OPS provided operators with significant and well-received feedback on areas for improvement

  20. Segment Identification Inspection Conclusions • Vigorous Enforcement is Being Pursued • While most operators appear headed toward sound program development, there are some areas that need to be improved. • NOAs are being used to communicate areas where improvement is needed. These do not necessarily represent a deterioration in the operator’s IM program as a whole. • Operators not taking IM requirements seriously face NOPV/Compliance Orders and Civil Penalties

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