EARLY EXPERIENCE WITH INTEGRITY MANAGEMENT INSPECTIONS FOR US HAZARDOUS LIQUID PIPELINE OPERATORS

摘要

In 2000 and 2002, the US Department of Transportation's Office of Pipeline Safety (OPS) published new regulations requiring integrity management programs for hazardous liquid pipeline operators. OPS had four fundamental objectives: 1) to increase the level of integrity assessments (i.e., in-line inspection or pressure testing) for pipelines that can affect high consequence areas; 2) to improve operator integrity management systems; 3) to improve government oversight of operator integrity management programs; and 4) to improve public assurance in pipeline safety. At the core of this new rule is a set of management-based requirements (referred to as "Program Elements" in the rule) that are fundamentally different from the existing, largely prescriptive pipeline safety requirements. The evaluation of operator compliance with these requirements requires the examination of management and analytical processes - aspects of operator's business that are not reviewed in standard OPS compliance inspections. OPS realized a fundamentally different approach to oversight was needed to assure operators are developing and implementing effective integrity management programs. This paper describes the comprehensive changes to the OPS inspection program that were developed to perform integrity management inspections. OPS completed the initial integrity management inspection of all large hazardous liquid pipeline operators in early 2004, and is making progress in reviewing the programs of smaller liquid operators. During this initial year OPS gained substantial knowledge about the state of hazardous liquid pipeline operator integrity management programs. At a high level, OPS learned that operators generally understand what portions of their pipeline systems can affect high consequence areas, and are making the appropriate plans and progress in conducting integrity assessments for these areas. However, the development of effective management and analytical processes, and quality data and information to support these processes takes time. While most operators appear to be headed in the right direction, fundamental changes to management systems require time. OPS recognizes this situation and has developed an inspection and enforcement approach that not only assures compliance with the rule requirements, but also fosters continuous improvement in operator integrity management programs. This paper describes the lessons learned from the initial inspections, and OPS expectations for future integrity management program development. Finally, the initial year of integrity management inspections provided some valuable insights about how to perform these new type of inspections and improve external communication. This paper also addresses what OPS learned about its inspection program, and how this program is being positioned to support on-going inspections of hazardous liquid operator integrity management programs.