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Inspection Program Improvements

Inspection Program Improvements. Peter Katchmar OPS Western Region May 17, 2005. Inspection Protocol Updates. Protocols re-examined for content and organization as part of inspection continuous improvement Changes focused on optimizing inspection efficiency and eliminating redundancy

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Inspection Program Improvements

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  1. Inspection Program Improvements Peter Katchmar OPS Western Region May 17, 2005

  2. Inspection Protocol Updates • Protocols re-examined for content and organization as part of inspection continuous improvement • Changes focused on optimizing inspection efficiency and eliminating redundancy • Updated protocols posted on IIM (http://primis.phmsa.dot.gov/iim/index.htm) • Cross-reference document posted on IIM

  3. Protocol Update Highlights • Process formality and revision control areas consolidated into new protocols 8.05 and 8.06 • Most protocol areas reduced in number of questions • For example, Segment Identification (Protocol area 1) now has eight questions vs. previous twelve

  4. Protocol Update Highlights • No changes to Remedial Action area (Protocol area 4) • Transferred “Installed Leak Detection System Information” protocol (6.05) to Operator Performance Data information sheet

  5. Protocol Update Highlights • Periodic Evaluations split out from “Periodic Evaluation and Assessment Intervals” (Protocol 7.01) • Reflects importance of 195.452(j)(2) as IMPs progress past baseline assessments • Rule requires frequency of periodic evaluations based on risk factors specific to the pipeline

  6. Protocol Update Highlights • 195.452(j)(2) contains a specific set of minimum information that periodic evaluations must consider • Assessment results (baseline and periodic) • Information/risk analysis • Remediation decisions • Preventive and mitigative actions decisions

  7. Areas of Emphasis in Future Inspections • Previously identified “opportunities for improvement” from past inspections • “Most Common” areas of identified issues • Previously discussed for each area • Overall “most common” list of issues

  8. Overall Most Common Issues Areas • Developing and implementing a systematic, documented process to evaluate additional preventive and mitigative measures to protect HCAs • Consideration of facilities (e.g., tanks) in risk analysis

  9. Overall Most Common Issues Areas • Development of a process to adequately train personnel responsible for reviewing assessment results • Integration of other pertinent data in a timely manner when evaluating assessment results

  10. Overall Most Common Issues Areas • Use of local knowledge, field personnel input, and other sources to update HCA information • Development of a comprehensive risk analysis process that considers all required risk factors • Inclusion of adequate detail in all areas of the integrity management plan

  11. Overall Most Common Issues Areas • Technical justification for pre-70 LF ERW or lap-welded pipe not being susceptible to seam integrity issues • Development of a documented EFRD needs analysis

  12. Overall Most Common Issues Areas • Documentation of the reasons for changes to the Baseline Assessment Plan • Development of ILI vendor specifications, including tool tolerance requirements and timeframes for completion of ILI reports

  13. Field Verification Inspections • Regions interested in verifying IM-related field activities. Examples: • HCA areas of interest • ILI actions • Repair and remediation activities • Installation or implementation of preventive and mitigative measures • Region-specific criteria for activities selected

  14. The End

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