Lessons Learned from Integrity Management Inspections Byron Coy – OPS Eastern Region Derick Turner – OPS Southern Region May 17, 2005

Lessons Learned from Lessons Learned from Integrity Management Integrity Management

InspectionsInspections

Byron Coy – OPS Eastern RegionByron Coy – OPS Eastern RegionDerick Turner – OPS Southern Derick Turner – OPS Southern

RegionRegionMay 17, 2005May 17, 2005

Summary of Experience to DateSummary of Experience to Date

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

Operators are generally able to Operators are generally able to meet repair deadlinesmeet repair deadlines

Progress is needed in Progress is needed in development of some IM Program development of some IM Program Elements, but this is expectedElements, but this is expected

Improved performance results Improved performance results from senior management support from senior management support and a commitment to continuous and a commitment to continuous improvementimprovement

Summary of Experience to DateSummary of Experience to Date

OPS successfully implemented a OPS successfully implemented a programmatic inspection approach programmatic inspection approach (vs. “yes/no” checklist)(vs. “yes/no” checklist) Measures to achieve consistency in Measures to achieve consistency in

identifying issues have been effectiveidentifying issues have been effective

OPS Perspective on Inspection OPS Perspective on Inspection ProcessProcess

Protocol application can be tailored Protocol application can be tailored to:to: Risk Risk

Leak historyLeak history Extent of HCA exposureExtent of HCA exposure

Pipeline system complexityPipeline system complexity IM process maturity and sophistication IM process maturity and sophistication Conservatism in assumptions and methodsConservatism in assumptions and methods Organization structure and complexityOrganization structure and complexity


Operator interactions have been Operator interactions have been generally cooperative with open generally cooperative with open communicationcommunication OPS provided operators with significant and OPS provided operators with significant and

well-received feedback on areas for well-received feedback on areas for improvementimprovement


Enforcement approach strives to Enforcement approach strives to promote operator program promote operator program development and ongoing development and ongoing improvementimprovement

Inspection approach continues to Inspection approach continues to improveimprove


Initial inspections may involve Initial inspections may involve significant “education” for some significant “education” for some operators of small systemsoperators of small systems

Operators of small systems may be Operators of small systems may be more likely to contract out more likely to contract out significant portions of IM program significant portions of IM program developmentdevelopment Operator is still ultimately responsibleOperator is still ultimately responsible

General Inspection ObservationsGeneral Inspection Observations

Program quality correlates better Program quality correlates better to corporate resources than to corporate resources than pipeline mileagepipeline mileage

General Inspection ObservationsGeneral Inspection Observations

ExperienceExperience Everything from Everything from

outlines to multi-outlines to multi-volume documentsvolume documents

Evidence of Evidence of compliance for compliance for completion completion sometimes missingsometimes missing

ExpectationsExpectations

IM Plan OrganizationIM Plan Organization

ExperienceExperience Everything from Everything from

outlines to multi-outlines to multi-volume documentsvolume documents

Evidence of Evidence of compliance for compliance for completion completion sometimes missingsometimes missing

ExpectationsExpectations Do not regurgitate the ruleDo not regurgitate the rule Not all processes have to Not all processes have to

be fully documented be fully documented within the IMP – can be within the IMP – can be referencedreferenced

Process should support the Process should support the implementation of a more implementation of a more consistent and thorough consistent and thorough approach approach

IM Plan OrganizationIM Plan Organization

ExperienceExperience Buffer zones of Buffer zones of

several sizesseveral sizes Some weak technical Some weak technical

justificationsjustifications Overland spill Overland spill

transport modelstransport models Simplifying Simplifying

assumptions for water assumptions for water transporttransport

Segment IdentificationSegment Identification


ExperienceExperience Buffer zones of Buffer zones of

several sizesseveral sizes Some weak technical Some weak technical

justificationsjustifications Overland spill Overland spill

transport modelstransport models Simplifying Simplifying

assumptions for water assumptions for water transporttransport

Segment IdentificationSegment Identification

ExpectationsExpectations Technical justification is Technical justification is

importantimportant Elaborate approaches Elaborate approaches

are not always are not always necessarynecessary

Use of field knowledge Use of field knowledge to capture all HCAsto capture all HCAs

May not need major re-May not need major re-reviewreview

ExperienceExperience Most Plans satisfactory, Most Plans satisfactory,

but some did not include but some did not include basic requirements – basic requirements – e.g., dates, assessment e.g., dates, assessment method, justificationmethod, justification

For ILI, Plans are For ILI, Plans are structured around structured around piggable sections – piggable sections – correlation with “could correlation with “could affect” segments affect” segments sometimes difficultsometimes difficult


Baseline Assessment PlanBaseline Assessment Plan

ExperienceExperience Most Plans satisfactory, Most Plans satisfactory,

but some did not include but some did not include basic requirements – basic requirements – e.g., dates, assessment e.g., dates, assessment method, justificationmethod, justification

For ILI, Plans are For ILI, Plans are structured around structured around piggable sections – piggable sections – correlation with “could correlation with “could affect” segments affect” segments sometimes difficultsometimes difficult

ExpectationsExpectations Spreadsheet or table Spreadsheet or table

can suffice as the plan can suffice as the plan 50% and 100% 50% and 100%

mileage requirements mileage requirements must be satisfiedmust be satisfied

Prioritization method Prioritization method can match complexity can match complexity and risk of system and risk of system used to establish a used to establish a scheduleschedule

Baseline Assessment PlanBaseline Assessment Plan

ExperienceExperience Broad spectrum of Broad spectrum of

approaches – GIS-approaches – GIS-based analytical tools based analytical tools to nothing at allto nothing at all

Data integration Data integration varies from computer varies from computer based to informal based to informal process to none process to none


Integrity Assessment Results Integrity Assessment Results ReviewReview

ExperienceExperience Broad spectrum of Broad spectrum of

approaches – GIS-approaches – GIS-based analytical based analytical tools to nothing at alltools to nothing at all

Data integration Data integration varies from computer varies from computer based to informal based to informal process to none process to none

ExpectationsExpectations Thorough review of Thorough review of

vendor ILI reports by vendor ILI reports by operator personneloperator personnel

Involve the experience/ Involve the experience/ expertise in the companyexpertise in the company

Integration with non-ILI Integration with non-ILI datadata

Document cause of Document cause of hydrotest failureshydrotest failures

Integrity Assessment Results Integrity Assessment Results ReviewReview

ExperienceExperience Timely vendor Timely vendor

reporting can be a reporting can be a problemproblem

Some lengthy times Some lengthy times between deformation between deformation and metal loss toolsand metal loss tools

Operators build in time Operators build in time to confirm defects are to confirm defects are “real” (e.g., not “real” (e.g., not previously repaired)previously repaired)


““Discovery”Discovery”

ExperienceExperience Timely vendor Timely vendor

reporting can be a reporting can be a problemproblem

Some lengthy times Some lengthy times between deformation between deformation and metal loss toolsand metal loss tools

Operators build in time Operators build in time to confirm defects are to confirm defects are “real” (e.g., not “real” (e.g., not previously repaired)previously repaired)

ExpectationsExpectations Expect operators to Expect operators to

promptly reduce pressure promptly reduce pressure for immediate repair for immediate repair conditionsconditions

Act on data from single tool Act on data from single tool if sufficient for discovery if sufficient for discovery and 2and 2ndnd tool delayed tool delayed

Document why discovery Document why discovery extends beyond 180 days extends beyond 180 days after assessment after assessment

““Discovery”Discovery”

ExperienceExperience Operators understand Operators understand

and are trying to meet and are trying to meet repair deadlinesrepair deadlines

Rule’s repair provisions Rule’s repair provisions not always in O&M not always in O&M proceduresprocedures

Some notifications when Some notifications when schedule can not be met schedule can not be met and pressure not and pressure not reducedreduced


Repair and RemediationRepair and Remediation

ExperienceExperience Operators understand Operators understand

and are trying to meet and are trying to meet repair deadlinesrepair deadlines

Rule’s repair provisions Rule’s repair provisions not always in O&M not always in O&M proceduresprocedures

Some notifications when Some notifications when schedule can not be met schedule can not be met and pressure not and pressure not reducedreduced

ExpectationsExpectations Records should clearly Records should clearly

show assessment, show assessment, discovery, and repair discovery, and repair datesdates

Feedback to ILI Feedback to ILI analyst of actual analyst of actual excavated defect excavated defect conditions and repair conditions and repair informationinformation

Repair and RemediationRepair and Remediation

ExperienceExperience Complicated Complicated

mathematical models to mathematical models to SME approachesSME approaches

Simple approaches for Simple approaches for prioritizing segments; prioritizing segments; more detailed methods more detailed methods for looking at segment-for looking at segment-specific threatsspecific threats

Justification for Justification for assumptions lackingassumptions lacking


Information/Risk AnalysisInformation/Risk Analysis

ExperienceExperience Complicated Complicated

mathematical models to mathematical models to SME approachesSME approaches

Simple approaches for Simple approaches for prioritizing segments; prioritizing segments; more detailed methods more detailed methods for looking at segment-for looking at segment-specific threatsspecific threats

Justification for Justification for assumptions lackingassumptions lacking

ExpectationsExpectations Systematic processSystematic process Comprehensive Comprehensive

consideration of consideration of threatsthreats

Inclusion of facilitiesInclusion of facilities Involvement of all Involvement of all

relevant operator relevant operator expertise/experience expertise/experience

Investigative approach Investigative approach

Information/Risk AnalysisInformation/Risk Analysis

ExperienceExperience Few operators had Few operators had

mature process for mature process for this elementthis element

Processes often not Processes often not well developed or well developed or documenteddocumented

Have seen few leak Have seen few leak detection and EFRD detection and EFRD evaluations evaluations


Preventive & Mitigative MeasuresPreventive & Mitigative Measures

ExperienceExperience Few operators had Few operators had

mature process for mature process for this elementthis element

Processes often not Processes often not well developed or well developed or documenteddocumented

Have seen few leak Have seen few leak detection and EFRD detection and EFRD evaluations evaluations

ExpectationsExpectations Consideration of Consideration of

potential preventive potential preventive and mitigative actions and mitigative actions – not assumption that – not assumption that existing programs are existing programs are enoughenough

Documented, risk-Documented, risk-based justificationbased justification

Leak Detection / EFRD Leak Detection / EFRD analysis to be in placeanalysis to be in place

Preventive & Mitigative MeasuresPreventive & Mitigative Measures

ExperienceExperience Few operators Few operators

considered periodic considered periodic evaluationsevaluations

Tendency to default Tendency to default to a 5 year to a 5 year assessment intervalassessment interval


Continual Evaluation and Continual Evaluation and AssessmentAssessment

ExperienceExperience Few operators Few operators

considered periodic considered periodic evaluationsevaluations

Tendency to default Tendency to default to a 5 year to a 5 year assessment intervalassessment interval

ExpectationsExpectations Baseline Plan Baseline Plan

transitions into an on-transitions into an on-going assessment plangoing assessment plan

For some lines For some lines assessment more assessment more frequently than 5 years frequently than 5 years is appropriate is appropriate


ExperienceExperience Wide variation in Wide variation in

how continuing how continuing evaluation is evaluation is approachedapproached

Some interval Some interval extension extension notifications notifications received by OPSreceived by OPS



ExperienceExperience Wide variation in how Wide variation in how

continuing evaluation continuing evaluation is approachedis approached

Some interval Some interval extension extension notifications received notifications received by OPSby OPS

ExpectationsExpectations Available techniques for Available techniques for

corrosion growth corrosion growth modeling, fatigue crack modeling, fatigue crack growth models may be growth models may be usefuluseful

Sound basis for Sound basis for treatment of seam treatment of seam integrity susceptibility, integrity susceptibility, SCCSCC


ExperienceExperience Little attention given to Little attention given to

this element this element Performance measures Performance measures

have mostly been have mostly been those in API-1160 – those in API-1160 – sometimes lesssometimes less

Some good approaches Some good approaches to root cause analysisto root cause analysis


IM Program EffectivenessIM Program Effectiveness

ExperienceExperience Little attention given to Little attention given to

this element this element Performance measures Performance measures

have mostly been have mostly been those in API-1160 – those in API-1160 – sometimes lesssometimes less

Some good approaches Some good approaches to root cause analysisto root cause analysis

ExpectationsExpectations Process in place by Process in place by

which the operator which the operator reviews its program reviews its program effectiveness (e.g., effectiveness (e.g., internal and external internal and external audits, management audits, management reviews)reviews)

Management Management awareness and awareness and supportsupport

IM Program EffectivenessIM Program Effectiveness

0

50

100

150

200

250N

um

ber

of

Issu

es

Program Element

Issues By Program Element

Common IM Program IssuesCommon IM Program Issues

0

5

10

15

20

25

30

35N

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of I

ssu

es

Segment Identification Issues Areas

Segment Identification IssuesSegment Identification Issues

Rank Issue Description

1

Failure to require use of local knowledge, fieldpersonnel input, and other sources to update

HCAinformation

2Failure to adequately document the segmentidentification results, process and

assumptions

3

Failure to adequately justify the buffer size used to

identify segments or facilities that could affect HCAs

4Failure to perform adequate water transport

analysiswhere applicable

5 Failure to adequately identify and locate HCAs

Segment Identification IssuesSegment Identification Issues

0

10

20

30

40

50

60

Nu

mb

er o

f Iss

ues

Baseline Assessment Plan Issues Areas

Baseline Assessment Plan IssuesBaseline Assessment Plan Issues

Rank

Issue Description

1Failure to technically justify why pre-70 LF ERW or lap-welded pipe is not susceptible to seam integrity issues

2Failure to document the reasons for changes to the BAP

3Failure to technically justify assessment method


Rank

Issue Description

4Failure to develop a BAP schedule that reflects the relative risk of the HCA affecting segments

5Failure to adequately specify assessment method(s) for all segments in the BAP

5Use of an incomplete risk evaluation for BAP scheduling that does not consider each of the relevant risk factors required by the rule


0

5

10

15

20

25

30

Num

ber

of Is

sues

Assessment Results Review Issues Areas

Assessment Results IssuesAssessment Results Issues

Rank

Issue Description

1Failure to develop a process to qualify personnel reviewing assessment results

2Failure to require the integration of other pertinent data in a timely manner, when evaluating assessment results

3Failure to specify adequate vendor specifications including tool tolerances and timeframes for ILI reports


Rank

Issue Description

4Failure to address the integrity assessment results review requirements in the IM plan or procedures

5

Failure to provide adequate assurance through calibration/verification digs, or other means, that tool data is valid and suitable for integrity-related analysis


0

5

10

15

20

25

30

35

Nu

mb

er

of

Iss

ue

s

Remediation Process Remediation Implement

Remedial Action Issues Areas

Remedial Action IssuesRemedial Action Issues

Rank

Issue Description

1Failure to adequately document compliance with repair rule criteria

2

Failure to require compliance with the ASME B31.4 Section 451.7 or document other acceptable pressure reduction methods when this code section is not applicable


Rank

Issue Description

3Failure to require implementation of time response requirements contained in the rule

4Failure to require pressure reductions for immediate repairs

5Failure to require prioritization of anomalies for repair


0

5

10

15

20

25

30

35

40

45

50

Nu

mb

er o

f Iss

ues

Risk Analysis Issues Areas

Information/Risk Analysis IssuesInformation/Risk Analysis Issues

Rank

Issue Description

1Failure to consider facilities (e.g., tanks) in risk analysis

2Failure to develop a comprehensive risk analysis process or consider all required risk factors

3Failure to require updates of the risk model for current conditions and environment

4Failure to adequately document the risk analysis process

5Failure to include explicit guidelines and process formality to support use of SME approach

Information/Risk Analysis IssuesInformation/Risk Analysis Issues

0

5

10

15

20

25

30

Nu

mb

er o

f Is

sues

Preventive and Mitigative Measures Issues Areas

Preventive & Mitigative IssuesPreventive & Mitigative Issues

Rank Issue Description

1Failure to have a systematic, documented process to evaluate additional measures to protect HCAs

2Failure to have a documented EFRD needs analysis

3Failure to document a leak detection evaluation process

4Failure to require a documented justification for decisions regarding additional preventive and mitigative measures

5Failure to consider risk analysis in making preventive and mitigative decisions

Preventive & Mitigative IssuesPreventive & Mitigative Issues

0

5

10

15

20

25

30

Nu

mb

er o

f Is

sues

Continual Assessment and Evaluation Issues Areas

Continual Assessment/Evaluation Continual Assessment/Evaluation IssuesIssues

Rank

Issue Description

1

Failure to develop or document an adequate periodic evaluation process that meets rule requirements

2

Failure to consider all relevant information or develop adequate justification for reassessment intervals

3

Failure to consider all relevant information or provide an adequate explanation of re-assessment methods


Rank

Issue Description

4Failure to develop or document a process for determining re-assessment intervals

5Failure to specify appropriate intervals to periodically evaluate the pipeline risks

5

Failure to prohibit reassessment intervals that exceed five years without adequate technical justification or notification of OPS


0

10

20

30

40

50

Num

ber

of Is

sues

Program Evaluation Issues Areas

Program Evaluation IssuesProgram Evaluation Issues

Rank

Issue Description

1Failure to provide adequate detail in all or most areas of the IM Plan

2Failure to develop adequate procedures for implementing the performance evaluation process

3

Failure to communicate the results of the Program Evaluation process to company personnel or third parties who need to make use of that information

4Failure to specify document retention periods or distribution requirements in the IM Plan

5Failure to require or perform root cause analyses of incidents that affect pipeline integrity

Program Evaluation IssuesProgram Evaluation Issues

Three rule instances in which Three rule instances in which operators can notifyoperators can notify Use of “Other Technology”Use of “Other Technology” Inability to meet repair schedules or reduce Inability to meet repair schedules or reduce

pressurepressure Interval longer than 5 yearsInterval longer than 5 years

First notifications received in May First notifications received in May 20022002

Notification ExperienceNotification Experience

36

22

13

3

0

5

10

15

20

25

30

35

40

Schedule Technology Interval Other

Notifications by Type


31

41

0

5

10

15

20

25

30

35

40

45

Intrastate Interstate

Notifications by Pipeline Category

16 of the notifications for intrastate pipelines involved pipelines in Texas


30

17

22

5

0

5

10

15

20

25

30

No Objection ObjectionsNoted

Not Required UnderReview

Notifications by Disposition


0

2

4

6

8

10

12

Number of operators

1 2 3 4 5 6 7 8

Number of notifications

Notifications by Operator

A total of 26 operators have submitted notifications


More Information:More Information:

http://primis.phmsa.dot.gov/iim/http://primis.phmsa.dot.gov/iim/notifications.imdnotifications.imd

OROR Go to the Implementing Integrity Go to the Implementing Integrity

Management (IIM) home page Management (IIM) home page -http://primis.phmsa.dot.gov/iim-http://primis.phmsa.dot.gov/iim Select Notifications/Notification ListingSelect Notifications/Notification Listing


The EndThe End

Documents

Lessons Learned from Integrity Management Inspections Byron Coy – OPS Eastern Region Derick Turner – OPS Southern Region May 17, 2005