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Office of Office of Pipeline Pipeline SafetySafety

Segment Identification Inspections

What did OPS Learn?


Presentation Topics

• Review Segment Identification Inspection Approach

• Summarize Inspection Results

° Segment Identification

° IM Program and Baseline Assessment Plan Development

• Communicate OPS Conclusions


IM Inspection Approach Overview

• Initial Segment Identification and Completeness Check

• Comprehensive Baseline Assessment Plan and IM Framework Review

• On-going Program Implementation Inspections


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


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


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


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


Segment Identification Results

• Percentage of Operator Mileage Identified that “Could Affect” HCAs = 39%

• Median = 44%

• Maximum = 100%

• Minimum = 0%


“Could Affect” Mileage

3 3

65

9

6

34

0

1

2

3

4

5

6

7

8

9

10

0-10% 10-20% 20-30% 30-40% 40-50% 50-60% 60-70% 100%

Total "Could Affect" Mileage as a Percentage of Total

Num

ber

of O

pera

tors


Segment Identification:Effect of Operator Size

"Could Affect" Mileage by Operator Total Mileage

40%51% 46% 40% 35%

0%

10%

20%

30%

40%

50%

60%

< 500 500-1000 1000 - 5000 5000-10,000 > 10,000

Total Operator Mileage

Perc

ent "

Coul

d Af

fect

"


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


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.


Segment Identification Enforcement

• OPS Demonstrated Commitment to Enforcement of the Integrity Management Rule

Operators 40

Operators with no compliance action

8

Operators receiving NOAs

31

Operators receiving NOPVs and CP

9

Operators receiving WL

1


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


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)


Baseline Assessment Plan Observations

• Weaknesses Observed in Some Operator Plans:

° Basis for Segment Priorities not Readily Evident

° Assessment Method Selection Criteria not documented


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


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



• 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



• 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