Managing the Notification Process

1. Managing the Notification Process Workshop on the Integrity Management Rule for Large Liquid Pipelines Beth Callsen August 7, 2001

2. OPS Posture • Flexibility for Credible, Evolving, Innovative Programs • Enforcement for Non-responsiveness • The Notification Process is not a Remedy for Bad Planning

3. Types of Notifications • Intent to Use “Other” Assessment Technologies • Inability to Meet Required Repair Schedule • Plan to Reassess Pipe Segment(s) Less Frequently than Every Five Years

4. Guiding Principles • OPS Will Review all Notifications and Respond (in a timely way) if They are Unsatisfactory • Notifications will be Subject to Factual Review During OPS Inspections • The Public will have Internet Access to Company Notifications and OPS Responses

5. Guiding Principles, continued • Submitting a Notification does not Eliminate Safety Related Condition Reporting Requirements • OPS will Provide Guidance on Minimum Information Needed to Facilitate a Response

6. As it Reviews NotificationsOPS will Consider • Operator Performance History • “Practical” Issues (Weather, Permitting Difficulties)

7. OPS Processing of Notifications • Managed out of OPS Headquarters • Involvement by Affected Regions • Notifications will Likely Lead to Enforcement Action Possible if Late, Incomplete or Technically Inadequate