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PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com Lessons Learned in MAOP Validation Process August 21, 2012 Chris Foley Vice President RCP Inc. PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Lessons Learned in MAOP Validation Process

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Lessons Learned in MAOP Validation Process. August 21, 2012 Chris Foley Vice President RCP Inc. PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com. Professional Engineering Consulting Firm. Pipeline Regulatory Compliance & Engineering - PowerPoint PPT Presentation

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Page 1: Lessons Learned in MAOP Validation Process

Lessons Learned in MAOP Validation Process

August 21, 2012

Chris FoleyVice President

RCP Inc.

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Page 2: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Professional Engineering Consulting Firm

• Pipeline Regulatory Compliance & Engineering– Asset / Compliance Management Software Applications– Pipeline Integrity Assessment Support– Acquisition Due Diligence– Long-Term Pipeline Compliance / Engineering Staff Support– Hydrotest Planning & Certification

• MAOP Services– MAOP Studies (as a service)– Turnkey MAOP Validation Services– MAOP Validation Software

Page 3: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Comprehensive Tool• MAOP calculator tool

– Analysis as a service & available to operators via license agreement– Comprehensive

• Gas/Liquid, Onshore/Offshore, Steel/Plastic, Federal/State/LOI’s• Identifies potential MAOP deficiencies

– Data gaps– Source documentation (gaps and/or questionable quality)– Differences in calculated MAOP vs. established MAOP

• Links source documents to data (Traceability)– Creates a traceable association between data and source documentation

• Accepts data sets in various formats (.xls, PODS, APDM)– Historical documentation / manual edits to existing data sets– .xls templates (RCP pre-configured or operator/3rd party developed)

• Customizable to fit operator terminology or other specific needs– GIS data models (impartial to type or version)

• Linear data (stationing/measurement) • Non-linear (distribution networks) tolerant

Page 4: Lessons Learned in MAOP Validation Process

•Preparation

•Pilot

•Execution

•Resolve Discrepancies

•Prioritize / Mitigate Problem Segments

•Ongoing Sustainable ProcessTurnkey MAOP Validation Process

Page 5: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Preparation• Evaluate current MAOP process• Determine document quality and grading standards

– Single vs. complimentary document types• Deliverables & sustainability goals

– Source document gaps, MAOP calculation variances, correct GIS data– Link source documents to MAOP calculated variables– Map process flow & update procedures

• Imaging– Electronic library

• Data repository– MAOP calculator / Reporting capabilities (slice & dice)

• Location for document review– Main office, field office, off-site

• # of people and their roles– Schedule, miles of pipeline, record quantity, record quality

Page 6: Lessons Learned in MAOP Validation Process
Page 7: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Pilot

• Small grouping– System location / type / pre or post regulation– Source document type

• Hydrotest, Alignment sheets• Source Documentation

– One touch philosophy– Organize / Index

• Test and improve MAOP validation process design

Page 8: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

MAOP Execution Process Flow Diagram

Source Documents Source Document Data Set

GIS Data (PODS, APDM, etc.) Combined MAOP Data Set (Raw)

Validated MAOP Data Set “Calculator Ready” MAOP Data Set

Source Document Imaging to Electronic

Library

RCP Document Review & Data Extraction

Capture MAOP Data to MaxOp®

Attach Cover Sheet and Return to Box

QC Box (Revise as Necessary)

Flag Issues That Require Operator Feedback

Operator SME Review and Gap Closure

Station Corrections

Pipeline Identification

“Smart” Segmentation

Assign Default Values

Resolve Data Gaps

Run MaxOp® Calculator MAOP Calculation ResultsEstablished MAOP vs. Calculated MAOPValidated MAOP Segments

Non-Validated MAOP SegmentsSource Document Grading Profile

Iterative Process Improvement Research & fill missing data gapsImprove document quality, if possibleUpdate data sets with better dataRe-run MAOP analysis & compare results vs. established MAOP

Update GIS data

Source Document Electronic Library

Page 9: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Document Review

• Source document data posted to MaxOpTM cover sheet• Unique ID assigned to each source document / folder / file• Bar code creates a traceable link from the data back to the

source document (scanned image)

Page 10: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Quality Control Challenges• Historical documentation

– Stationing listed (if any) may not match current GIS standards– Unsure if the document is the most current for that segment

• Ex. HQ alignment sheets vs. redlines @ field offices– Filing structure isn’t conducive to limiting research to Class 3 & 4 and HCA’s

• Organized by WO / AFE#• Merging of GIS & Historical documentation

– What is the source of the electronic data (GIS, risk, .xls, ILI, etc.)?– Historical takes precedence unless otherwise determined by operator (PHMSA ADB)– Terminology of documentation not matching GIS terminology

• Ex. line identification – Line #2 South TX Jct. vs. Route Code 12345• Expertise of Document Review & QC Personnel

– Natural trade-off’s between quantity, speed, quality & cost– Steep learning curve, must be willing to invest in strong training & QC process– Document review can be tedious; must let those who have mastered this process to

promote up to QC / other roles

Page 11: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Discrepancy Resolution• PHMSA ADB 12-06

– Annual report due 3-15-2013– Class 3 & 4 and HCAs in Class 1 & 2 (Annual Report NOPR?)

• Gaps in source documentation– Poor quality document grades

• Calculated MAOP < Established MAOP• Are there newer or higher quality source documents

elsewhere (“Complimentary Documents”)?• Linear reference & stationing issues• Non-linear (distribution system) replacement projects

– Old source document replaced with new one

Page 12: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Identify Potential MAOP Deficiencies

Page 13: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Prioritize & Mitigate “Problem Segments”

• What is PHMSA’s next step after the 2013 annual report?– PHMSA Annual Report Revisions NOPR (4/13/2012)

• All transmission mileage validated (not just class 3&4 and class 1&2 HCA)• Deadline March 15, 2013 (not July 3, 2013 per PHMSA reauthorization

bill)– Industry Comments

• Hydrotest or other?– Anyone want to go in w/me to buy/build hydrotest company?!?!

• Schedule and priority?– Likely some risk-based approach

Page 14: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

NOPR Annual Report Section Q

Page 15: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

NOPR Annual Report Section R

Page 16: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

SustainabilityWork / Asset Management Systems

• Link source documents to MAOP data– GIS (PODS, APDM, other)– MAOP Data Books (hard copy vs. electronic)

• Develop/improve MAOP procedures– Data capture– Data repository– Responsibilities

• Don’t want to repeat this effort!

Page 17: Lessons Learned in MAOP Validation Process

PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS. www.rcp.com

Questions?

Chris FoleyRCP Inc.

Vice [email protected](713) 655-8080