current inspection process for operators of hazardous liquids pipelines rod seeley ops sw region...
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Current Inspection Process Current Inspection Process for Operators offor Operators of
Hazardous Liquids Hazardous Liquids PipelinesPipelines
Rod SeeleyRod SeeleyOPS SW Region DirectorOPS SW Region Director
May 18, 2005May 18, 2005
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Goals of Future IMP InspectionsGoals of Future IMP Inspections
Continuous improvement in OPS IMP Continuous improvement in OPS IMP inspection processinspection process
Seamless inspection process to Seamless inspection process to OperatorsOperators
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OPS Liquid IMP Inspection OPS Liquid IMP Inspection Organizational ChangesOrganizational Changes
Management of IM inspection Management of IM inspection program has shifted from OPS program has shifted from OPS Program Development to OPS Program Development to OPS RegionsRegions
OPS Program Development will OPS Program Development will monitor the inspection process and monitor the inspection process and identify significant trendsidentify significant trends
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Seamless Transition in Seamless Transition in Inspection ProcessInspection Process
OPS SW Region to lead Liquid IMP OPS SW Region to lead Liquid IMP inspections of many large Operators with inspections of many large Operators with jurisdictional assets in multiple Regionsjurisdictional assets in multiple Regions
Change should be seamless to OperatorsChange should be seamless to Operators All OPS Regions participating in and/or All OPS Regions participating in and/or
directly supporting SW Region-lead directly supporting SW Region-lead inspections for large multi-region inspections for large multi-region OperatorsOperators
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Inspection ProcessInspection Process
Inspection process is the same for all Inspection process is the same for all Operators and follows the format Operators and follows the format used in first round of IMP inspectionsused in first round of IMP inspections Pre-inspection meeting or Pre-inspection meeting or
teleconferenceteleconference Inspection (approximately two weeks)Inspection (approximately two weeks) Exit interview at conclusion of inspectionExit interview at conclusion of inspection
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Continuous Improvement in Continuous Improvement in OPS IMP Inspection ProcessOPS IMP Inspection Process
Implemented systematic processes Implemented systematic processes for the conduct of IMP inspectionsfor the conduct of IMP inspections
Revised inspection protocols and Revised inspection protocols and Inspector guidance materialsInspector guidance materials
Utilizing previous inspection results Utilizing previous inspection results in preparation for IMP inspections in preparation for IMP inspections
Current Inspection Process Current Inspection Process for Operators offor Operators of
Hazardous Liquids Hazardous Liquids PipelinesPipelines
Chris McLarenChris McLaren
OPS SW RegionOPS SW Region
May 18, 2005May 18, 2005
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Talking PointsTalking Points
Lessons learnedLessons learned IMP inspection formatIMP inspection format Areas of improvementAreas of improvement Consensus standardsConsensus standards Path forwardPath forward
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Operators generally understand and Operators generally understand and are implementing the assessment are implementing the assessment provisions of the ruleprovisions of the rule
Progress is needed in development Progress is needed in development and implementation of several IMP and implementation of several IMP elementselements Preventive & mitigativePreventive & mitigative Leak detection and EFRD analysesLeak detection and EFRD analyses Periodic evaluationsPeriodic evaluations Re-assessment interval determinationRe-assessment interval determination Program evaluationProgram evaluation
Lessons Learned from First Round Lessons Learned from First Round IM InspectionsIM Inspections
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Improved performance results from a Improved performance results from a commitment to continuous improvementcommitment to continuous improvement
Operator interactions have been Operator interactions have been generally cooperative with open generally cooperative with open communicationcommunication
Inspection approach continues to Inspection approach continues to improve with the use of protocol driven improve with the use of protocol driven inspectionsinspections
Lessons Learned from First Round Lessons Learned from First Round IM InspectionsIM Inspections
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All OPS Regions participating in and All OPS Regions participating in and supporting SW Region-lead supporting SW Region-lead inspections for large multi-region inspections for large multi-region OperatorsOperators
IMP related field activities and Region-IMP related field activities and Region-specific issues identified during status specific issues identified during status update meetings and IM inspections update meetings and IM inspections for follow-up by individual Regionsfor follow-up by individual Regions
OPS Organizational ChangesOPS Organizational Changes
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IMP status update meetingsIMP status update meetings Scheduling of inspectionsScheduling of inspections Performance of inspections using Performance of inspections using
revised inspection protocolsrevised inspection protocols Documentation requirementsDocumentation requirements Reporting requirementsReporting requirements
2005 Inspection Format2005 Inspection Format
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IMP Status Update Meetings IMP Status Update Meetings conducted at SW Region with nine conducted at SW Region with nine large liquid multi-region Operators large liquid multi-region Operators being inspected by the SW Region in being inspected by the SW Region in 20052005
Operator IMP improvements since Operator IMP improvements since previous inspection discussedprevious inspection discussed
OPS expectations for next inspection OPS expectations for next inspection discusseddiscussed
Performed pre-inspection activitiesPerformed pre-inspection activities
Status Update MeetingsStatus Update Meetings
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Provide opportunity for Operators to Provide opportunity for Operators to discuss specific concerns and areas discuss specific concerns and areas of uncertainty with OPSof uncertainty with OPS
Ensure appropriate inspection Ensure appropriate inspection resources are allocatedresources are allocated
Operator IMP-related field activities Operator IMP-related field activities identified on Regional basis to assist identified on Regional basis to assist resource allocation (e.g., witness resource allocation (e.g., witness implementation tasks – integrity implementation tasks – integrity assessments, repair and assessments, repair and rehabilitation, EFRD installation, etc.)rehabilitation, EFRD installation, etc.)
Status Update MeetingsStatus Update Meetings
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2005 Schedule Considerations2005 Schedule Considerations Date of previous inspectionDate of previous inspection OPS and operator personnel schedulingOPS and operator personnel scheduling Conclusion dates of any major Conclusion dates of any major
assessment/remediation programsassessment/remediation programs Timing of significant Timing of significant
mergers/acquisitionsmergers/acquisitions Anticipated closing of any relevant open Anticipated closing of any relevant open
enforcementenforcement Date of implementation of IMP-related Date of implementation of IMP-related
projects (e.g. GIS, work order systems)projects (e.g. GIS, work order systems)
Scheduling of InspectionsScheduling of Inspections
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Flexibility from participants was needed Flexibility from participants was needed in the inspection scheduling processin the inspection scheduling process
Future scheduling of IMP team Future scheduling of IMP team inspections to be done prior to status inspections to be done prior to status update meetings to alleviate update meetings to alleviate scheduling issuesscheduling issues
Scheduling of InspectionsScheduling of Inspections
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IMP needs to have matured from IMP needs to have matured from framework status into detailed process framework status into detailed process descriptionsdescriptions
All protocols will be used during All protocols will be used during inspectionsinspections
Results of the previous inspection will be Results of the previous inspection will be utilized as applicableutilized as applicable
Anticipated to take two weeksAnticipated to take two weeks
IMP InspectionIMP Inspection
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Use of revised protocols dated Use of revised protocols dated December 31, 2004 on OPS websiteDecember 31, 2004 on OPS website
Spreadsheets for operator Spreadsheets for operator performance data acquisition performance data acquisition revisedrevised Liquid operator program information form Liquid operator program information form
now includes leak detection systems data now includes leak detection systems data (Protocol 6.05 removed and incorporated (Protocol 6.05 removed and incorporated here)here)
IMP InspectionIMP Inspection
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2020
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Exit interview used for Exit interview used for communication to Operator of communication to Operator of strengths and weaknesses of IMP strengths and weaknesses of IMP identified during inspectionidentified during inspection
Communication to OPS Regions of Communication to OPS Regions of possible field verification activities possible field verification activities identified during the inspectionidentified during the inspection
Documentation of IMP inspectionDocumentation of IMP inspection
Post Inspection ActivitiesPost Inspection Activities
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Summary Report (reviewed by Operator Summary Report (reviewed by Operator for factual content prior to finalization)for factual content prior to finalization)
Electronic format of IMP is extremely Electronic format of IMP is extremely helpful in completing OPS helpful in completing OPS documentation requirementsdocumentation requirements
All documents not included in reports All documents not included in reports and/or enforcement returned or and/or enforcement returned or disposed of at conclusion of inspection disposed of at conclusion of inspection processprocess
Inspection DocumentationInspection Documentation
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Evaluation of leak detection Evaluation of leak detection capabilitiescapabilities
Implementation of preventive and Implementation of preventive and mitigative measuresmitigative measures
EFRD need determinationEFRD need determination Re-assessment interval determinationRe-assessment interval determination Program performance evaluationProgram performance evaluation
Areas of ImprovementAreas of Improvement
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Evaluation of corrosion control Evaluation of corrosion control programs and their input into risk programs and their input into risk analysis and integration with analysis and integration with integrity assessment resultsintegrity assessment results
QA/QC processesQA/QC processes Verification of data in risk analysis and use of Verification of data in risk analysis and use of
data obtained from OM&I tasksdata obtained from OM&I tasks Review of integrity assessment results and Review of integrity assessment results and
other vendor supplied dataother vendor supplied data
Areas of ImprovementAreas of Improvement
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StandardStandard StatusStatus CommentsComments ScheduleSchedule
ASME B31.8S – ASME B31.8S – 2001 2001 Integrity Integrity ManagementManagement
Revisions in Revisions in processprocess
Modify ECDA section Modify ECDA section and add CDA. May and add CDA. May have to wait on new have to wait on new RP0502RP0502
ASME B31QASME B31QQual. of PersonnelQual. of Personnel
Drafting StandardDrafting Standard Work started in August Work started in August - 2003- 2003
Est. completion Est. completion Q4 2005Q4 2005
NACE RP0502-2002NACE RP0502-2002Pipeline ECDAPipeline ECDA
Published 2002Published 2002 Revisions to be Revisions to be considered at NACE considered at NACE Spring MeetingSpring Meeting
Revisions in 2005Revisions in 2005
NACE RP0102-2002 NACE RP0102-2002 In-Line Inspection of In-Line Inspection of PipelinesPipelines
Updating/Updating/RevisionsRevisions
Modify to compliment Modify to compliment API 1163, TG 212 API 1163, TG 212 ReestablishedReestablished
Revisions in 2005Revisions in 2005
NACE – TG315NACE – TG315ICDA for Liquid ICDA for Liquid Petroleum PipelinesPetroleum Pipelines
Development in Development in processprocess
ICDA especially for ICDA especially for crude oil systemscrude oil systems
Draft not Draft not completed. completed. Completion date Completion date undeterminedundetermined
Industry Consensus StandardsIndustry Consensus Standards
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Industry Consensus StandardsIndustry Consensus Standards
StandardStandard StatusStatus CommentsComments ScheduleSchedule
NACE – RP-0204 - NACE – RP-0204 - Pipeline SSCDAPipeline SSCDA
Development in Development in processprocess
Addresses high pH and Addresses high pH and near-neutral pHnear-neutral pH
Complete in Complete in 20042004
API 1110 – Pressure API 1110 – Pressure Testing of PipelinesTesting of Pipelines
CompletedCompleted Standard on pressure Standard on pressure testing new and existing testing new and existing pipelinespipelines
CompletedCompleted
API 1163 - ILI API 1163 - ILI Systems Systems QualificationsQualifications
Development in Development in processprocess
Balloting/Public CommentBalloting/Public Comment Publish – Q2 Publish – Q2 20052005
ASNT ILI PQ – 2003 ASNT ILI PQ – 2003 ILI Personnel Qual. & ILI Personnel Qual. & Cert.Cert.
CompletedCompleted In Balloting/ Public In Balloting/ Public CommentComment
Publish – Q2 Publish – Q2 20052005
API 1162API 1162Public Public CommunicationsCommunications
Approved / In Approved / In PublicationPublication
NPRM issued Q2 for NPRM issued Q2 for inclusion in regulationsinclusion in regulations
Approved – Q3 Approved – Q3 20032003
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Integrity management is a continuous Integrity management is a continuous improvement regulationimprovement regulation
OPS is committed to developing and OPS is committed to developing and implementing improved tools and implementing improved tools and techniques as inspection process techniques as inspection process evolvesevolves
Operator feedback / perspective of Operator feedback / perspective of which methods are effective and which which methods are effective and which methods are not effective is important methods are not effective is important to OPSto OPS
Path ForwardPath Forward
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Continue to improve inspection process and Continue to improve inspection process and standardization of documentation and standardization of documentation and communication channelscommunication channels
Ensure inspections are consistently performed Ensure inspections are consistently performed and IM Rule is consistently applied during and IM Rule is consistently applied during inspection processinspection process
Field verification of IMP activitiesField verification of IMP activities Complete “second round” of IMP inspections Complete “second round” of IMP inspections
by 2007by 2007
Path ForwardPath Forward
The EndThe End