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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
OPS Perspective on Inspection OPS Perspective on Inspection ProcessProcess
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
OPS Perspective on Inspection OPS Perspective on Inspection ProcessProcess
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
OPS Perspective on Inspection OPS Perspective on Inspection ProcessProcess
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
ExpectationsExpectations
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
ExpectationsExpectations
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
ExpectationsExpectations
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)
ExpectationsExpectations
““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
ExpectationsExpectations
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
ExpectationsExpectations
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
ExpectationsExpectations
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
ExpectationsExpectations
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
Continual Evaluation and Continual Evaluation and AssessmentAssessment
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
ExpectationsExpectations
Continual Evaluation and Continual Evaluation and AssessmentAssessment
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
Continual Evaluation and Continual Evaluation and AssessmentAssessment
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
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
um
ber
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
Baseline Assessment Plan IssuesBaseline Assessment Plan Issues
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
Baseline Assessment Plan IssuesBaseline Assessment Plan Issues
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
Assessment Results IssuesAssessment Results Issues
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
Assessment Results IssuesAssessment Results Issues
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
Remedial Action IssuesRemedial Action Issues
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
Remedial Action IssuesRemedial Action Issues
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
Continual Assessment/Evaluation Continual Assessment/Evaluation IssuesIssues
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
Continual Assessment/Evaluation Continual Assessment/Evaluation IssuesIssues
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
Notification ExperienceNotification Experience
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
Notification ExperienceNotification Experience
30
17
22
5
0
5
10
15
20
25
30
No Objection ObjectionsNoted
Not Required UnderReview
Notifications by Disposition
Notification ExperienceNotification Experience
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
Notification ExperienceNotification Experience
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
Notification ExperienceNotification Experience
The EndThe End