Update on Hazardous Liquid Integrity Management Inspections for US Operators

Abstract

The US Department of Transportation’s Pipeline Hazardous Materials Safety Administration (PHMSA) started the second round of integrity management inspections on hazardous liquid pipeline operators in mid-2005. Since then PHMSA has used the information gained from all of the Hazardous Liquid Integrity Management (HL IM) inspections to continue the development of the HL IM inspection process. 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. The fundamental objectives for HL IM have not changed: 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. The IM rule is based on a set of management-based requirements (referred to as “Program Elements” in the rule) that are fundamentally different from the previously existing, largely prescriptive pipeline safety requirements. The evaluation of operator compliance with these requirements requires the inspection of management and analytical processes - aspects of operator’s business that are not reviewed in standard PHMSA compliance inspections. PHMSA has gained significant experience with the fundamentally different approach to oversight needed to assure operators are developing and implementing effective integrity management programs. This paper describes the lessons learned from the inspections themselves and from basic changes in the management of the HL IM inspection program. PHMSA completed the initial integrity management inspection of all large hazardous liquid pipeline operators in 2004 and has continued inspecting both small system IM operators and re-inspecting large operators. As of December 2005 PHMSA has completed the inspection of 175 first round interstate hazardous liquid pipeline operators of which 101 are interstate systems and 74 are programs of intrastate hazardous liquid operators. Additionally, 14 second round inspections of hazardous liquid operators have been performed. Since the initial pilot hazardous liquid integrity management (HL IM) inspections in 2002 PHMSA has found that operators generally understand what portions of their pipeline systems can affect high consequence areas, and have made significant progress in conducting integrity assessments for these areas (Figure 1). However, the development of effective management and analytical processes, and quality data and information to support these processes still requires considerable attention from some operators. While most operators appear to be headed in the right direction, fundamental changes to management systems require time and management commitment. PHMSA recognizes this situation and continues to develop and implement an inspection and enforcement approach that seeks to assure compliance with the rule requirements and continuous improvement in operator integrity management programs. Finally, after several years of integrity management development and associated inspections PHMSA gained additional experience about how to perform this new type of inspection. An important change in the program took place in late 2004 when the PHMSA regions took over the scheduling, inspection program, and other aspects of managing the IM inspections. This paper also addresses what PHMSA learned about its inspection program, and how this program is being positioned by the regions to support on-going inspections of hazardous liquid operator integrity management programs.