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3.

Integrity Assessment
1. Segment Identification
Results Review Integrity Management
Integrity Management
Inspection Protocol Overview
1.01 HCA Identification Inspection Protocol Overview
3.01 Qualifications
2. Baseline
1.02 Direct Intersection of Reviewers
Assessment Plan
Method and Exceptions
3.02 ILI Vendor Specs
1.03 Release Locations
and Spill Volumes 3.03 Validation of
2.01 Assessment Assessment Results
1.04 Overland Spread of Method
Liquid Pool 3.04 Integration of
Other Information with
1.05 Water Transport Assessment Results 4. Remedial Action
Analysis 2.02 Prioritized
1.06 Air Dispersion Analysis Assessment 3.05 Identifying and
Schedule Categorizing Defects
1.07 Identification of Segments
4.01 Process
that Could Indirectly Affect an 3.06 Hydrostatic Test
HCA
1.08 Timely Completion of 2.03 Prior 3.07 Other Assessment
Segment Identification Assessments Technologies 4.02 Implementation

IM Program Integrity
Elements Assurance
5.01 Comprehensiveness 6.01 Actions Considered 7.01 Periodic Evaluation 8.01 Process Approach
of Approach
7.02 Re-assessment Intervals
6.02 Application of Risk 8.02 Performance Metrics
5.02 Integration of Risk Analysis 7.03 Assessment Methods
Information 8.03 Communication of
7.04 Assessment Interval
6.03 Decision Basis Variance Evaluation Results
5.03 Input Information
6.04 Leak Detection: 7.05 ECDA Pre-Assessment 8.04 Root Cause Analysis
5.04 Risk Analysis of Evaluation Factors
Segments that Could 7.06 ECDA Indirect Inspection
8.05 Process Revision
Affect HCAs 6.05 Leak Detection: 7.07 ECDA Direct Examination and Document Control
Operator Actions/Reactions
5.05 Results
7.08 ECDA Post Assessment 8.06 Process Formality
6.06 EFRD: Evaluation
5.06 Facilities Risk Factors
Analysis 7. Continual Process of
8. Program Evaluation
Evaluation and Assessment
6. Preventive and
5. Risk Analysis Mitigative Actions
Segment Identification
Additional Guidance Overview
1.03 Release Locations and Inspection of Implementation and
Spill Volume Results of Segment Identification
Analysis
Water Crossings
Review
1.02 Direct Intersection Topography 1.04 Overland Spread NPMS
Method and Exceptions of Liquid Pool HCAs Definitions from Other Sources
1.01 HCA Identification Distance to HCA Release Volume Calculations
Transport Analysis Calculations
Define Intersection Fixed Spacing Justification for Assumptions
Valid Assumptions
Endpoints (Including Buffer Zones)
Facilities Spreadsheets or Other Listing of
NPMS
Topography Segment Endpoints
Facilities Failure Size
Operator Maps/GIS
Operating Conditions Spill Response
Computer Analysis
Methodology Actions
Local Detection &
Knowledge Response Time
Manual Analysis Local Factors
Methodolgy Drain Down (Ditches, Farm
Tiles, etc.)
Release Rate
Rigorous and Valid (Imp. for HVL) All
Periodic Technical Justification Valid Computer
Updates of Exceptions Design Factors Modeling Techniques Segments
that
Could
Stream Conditions, Flow Applicability (HVL, Applicable Analysis Factors Category 1 Pipe (12/31/01)
Characteristics, Change in Special Cases for per 1.04 through 1.08
Affect
Properties of Commodity in Water Certain non-HVLs) HCAs
Segments Identified by Category 2 Pipe (11/18/02)
Specific Factors to Selection of Specific Endpoints
Consider such as MTBE, Analysis Model and Category 3 Pipe (Before Ops)
Buoyancy, Solubility, Off- Software Tool Buffer Zone Identifies All
gassing (H2S), etc. Locations Within Buffer
Modeling of Physical Distance 1.08 Completion by
Indirect Introduction Into Properties Deadline
Water via Overland Technical Justification for
Spread or Spray Valid Inputs and Exceptions if HCA is
Assumptions Closer than Buffer Zone
Distance Segment Identification
Valid Assumptions Process Inspection
Threshold LOC
Facilities Review
Spill Response Actions
Secondary Effects IM Program Documentation
1.07 Identification of Segments Policy Documents
Implementing Procedures
1.05 Stream/Water that Could Indirectly Affect an HCA
Software Documentation
Transport Analsysis 1.06 Air Dispersion Analysis
Baseline Assessment Plan
Additional Guidance Overview

2.01 Assessment Methods 2.02 Prioritized Assessment Schedule

Methods Appropriate for Pipeline All "Could Affect"


Specific Risk Factors Segments Scheduled
ILI Tools that Detect Corrosion 50% Progress Milestone
and Deformation Anomalies 100% Completion Milestone
Schedule Appears
Acceptable Method per 452 (c) Reasonable & Achievable
Higher Risk Segments
Methods for Low Freq ERW or Assessed First
Lap Welded Pipe Susceptible Consideration of All Risk Factors,
to Longitudinal Seam Defects Including those in 452 (e)
Method Capable of Detecting Cracks for In Cases Where Assessment Sections
Include Multiple "Could Affect" Segments:
Pipeline with Known Crack Risk Factors
Explanation of Method to Aggregate Data in Part K of the most recent Form
90-Day Notification for Segments and Establish Priorities
Other Technology PHMSA F 7000-1.1 appear valid and completed

Corrosion Control Effectiveness for


Pressure Tested Segments Timely and
Accurate
Assessment of
Pipeline Integrity
Prior Assessments Must
Use Methods Acceptable
Under 452 (c)

Assessments Completed Before Inspection of Baseline Assessment


1/1/96 (Category 1) or 2/18/97 Plans
(Category 2) are not Allowed
Review
Baseline Assessment Plan
Segment Listing
2.03 Prior Assessments Risk Ranking
Risk Drivers
Capabilities of Tools Selected
Justification for Assessment
Method Selection
Schedule Details
Completion Progress
Baseline Assessment Plan
Revisions
Integrity Assessment Results Review
3.02 ILI Vendor Specs Additional Guidance Overview
Tool Vendor Services
& Accountability 3.03 Validation of
Tool Specs (incl. Assessment Results
Tolerances) Review of Assessment Results
Process Inspection
Vendor Reporting Selection of
Within 180 Days Verification Digs Review
3.01 Qualifications of
Reviewers IM Program Documentation
Immediate Reporting
Procedures for Interacting with
of Imminent Threats Collection, Vendor
Documentation & Procedures for Supporting ILI
Qualification Criteria/Threshold for Dissemination of Including Tool Run, Preliminary
Requirements Vendor Reporting of Info from Dig Review of Data, Validation Digs,
Anomalies
etc.
Procedures for Verification of Procedures for Conducting Hydros
Current Level
Interaction wi/ Vendor Anomaly Location Procedures for Review of
of Qualification
and Skills Assessment Results (Both ILI and
Variances to Vendor Hydro) and Analyzing Data
Performance Specs Documented Historical
Plan and Schedule to or Analytical Basis for
Achieve Required Qualifications of Not Performing
Qualification Vendor Personnel Verification Digs
Identification
of Integrity
Additional Data Sources (CIS, ROW, Discovery within Documentation of Cause
Criteria for Threats
Selection of Other
CP, One-Call, Tool Tolerance, 180 Days of Test Failures
Technology
Design, Construction, Operations,
Maintenance, Repair, etc.)
Categorize per Accepted Industry
Metallurgical Evaluation
452 (h) Criteria of Test Failures Practices/Standards
Collection & Dissemination of
Info to Persons Reviewing Inspection of Assessment Records and the
Assessment Results Operator's Review of Assessment Records
Definition of When Analysis of Method to Validate
"Discovery" Occurs Pressure Reversals Results (Including the Integrated Review with Other
Systematic Integration of
Information)
Data with ILI Results
Actions Required if Records Demonstrating Procedures for Review
New Industry or
Review of Assessment Compliance with Subpart E Excavations Vendor Assessment Reports
Accident Info
Results Cannot Be Excavation Records
Documented Results of Completed within 180 Basis for Test Other Information Analyzed in Conjunction
Days of Assessment Reporting with Assessments Results
Integrated Info Analysis Acceptance and Requirements
Validity Conclusions and Resulting Actions
and Discovery Records containing anomaly data,
Identification of Integrity
including date of discovery, anomaly type,
Threats or Trends
characteristics, repair category, location,
3.05 Identifying & 3.06 Hydrostatic 3.07 Other date of repair, and other risk factor data.
Categorizing Defects Test Technology Data Integration Software or Records/GIS
3.04 Integration of Other
Information with
Assessment Results
Remedial Action
4.01 Remedial Action Process Additional Guidance Overview

Prioritized Remediation Schedule

Documented Justification that Changes Remedial Action


to Repair Schedule will Not Jeopardize Process Inspection
Public Safety or the Environment
Review
IM Program Documentation
Notification if Repair Schedule Can Not O&M Manual
Be Met and Pressure is Not Reduced Repair Procedures
Procedures for Determining Repair
Schedule Priorities
Pressure Reduction for Immediate Repair Conditions

Limitation of Pressure Reduction to 365 Days

Repairs Comply with 49 CFR 195.422

Recordkeeping for Repairs Repair or


Remediation
of Integrity
Prioritized Schedule Developed
Threats
Repairs Accomplished per the Prioritized Schedule

Any Schedule Changes Documented and Demonstrated not to


Pose a Risk to Safety or the Environment
Inspection of Implementation for
Notifications and Justification Remedial Action

Pressure Reduction or Shutdown for Immediate Repair Conditions Review


Repair Records
Excavation/Remediation Schedule
Pressure Reduction Determined via ANSI B31.4 Documentation of Changes to Repair
Section 451.7 or other Valid Engineering Basis Schedule
Notifications
Pressure Reduction Remained in Place No More Than 365 Days Operating Records (Pressure
Reductions)
Calculations of Safe Operating
Repairs Made per 49 CFR 195.422 Pressure

Data in Part J of Form PHMSA F 7000-1.1 valid and complete

4.02 Remedial Action Implementation


Risk Analysis
Additional Guidance Overview
5.02 Integration of Risk
Information 5.03 Input Information

Input Data Needed to Assessment Results Inspection of Implementation for Risk


5.01 Comprehensiveness Characterize Risk Factors Analysis Activities
of Approach Accuracy of Data
Review
Justification for Analytical
Input Data
Tool, Model, or Algorithm
Risk Factors Related Assurance of Completeness Segment Specific Risk Calculations
& Quality of Data & Scores
to Integrity Threats
Structured Process & Guidelines Analysis Results
Segment Rankings
Appropriate Use of Excessively Risk Driver Reports
Justification for Weighting Factors Conservative Data Graphical Display of Results
Risk Factors Related
to Consequences
Risk Integration Process that Structured Process for
Emphasizes Safety & Environment Subjective Input Data

Integration with "Could Integration of Other Factors Operator & Industry


Affect" Analysis Not Included in Risk Model Operating Experience Data
Identification
of Pipeline
Uniform Risk Characteristics Highest Risk Locations Documented Risks
Approach for Risk
Analysis of Facilities
Important Risk Drivers
Approach for Application of Risk
Factors that Vary Across the
Pipeline Unit Being Analyzed Results Useful in Risk Analysis
Differentiation of Relative Risk
Determining Actions Process Inspection
Among Pipeline Segments
to Reduce Risk
Review
IM Program Documentation
Process for Relating Pipeline All Modes of Operation 5.06 Facilities Policy Documents
Subdivision Units Used in Risk
Implementing Procedures
Analysis to (1) Sections Defined for
Selection of Risk Factors to
Assessments and (2) Segments
that Could Affect HCAs Uncertainty Evaluation & Resolution Analyze
Software Documentation
Risk Model Descriptions
5.05 Meaningful Results Algorithms/Formulae
5.04 Risk Analysis of Pipeline
Justification for Weighting
Could Affect HCA Segments Factors
Input Data Sources
Additional Preventive & Mitigative Actions
Additional Guidance Overview

6.01 Actions Considered


6.03 Decision Basis
6.02 Application of Risk
Significant Causes Analysis Additional Preventive & Mitigative Actions
Systematic Decision-
& Risk Drivers Process Inspection
Making Process
Analysis of All Risk Factors Review
Broad Sprectrum of Priority on Highest Risk
in 451(i)(2) - Exceptions IM Program Documentation
Potential Actions, Incl. Lines & Facilities
Must Be Justified Procedures
Those Listed in 452(i)(1)
Process for Identifying & Evaluating
Analysis of All Other Risk Basis for Risk Control Measures
Effectiveness of Current Programs Criteria for Decision-Making
Risk Factors That Decision-Making
Could Pose a Threat Leak Detection System Documentation
Consider Spectrum of Actions Documentation of All
Address Consequences Candidate Actions Considered
Consider Both Physical Mods of Failures
and Procedural Changes Implementation of Approved Identify
Assurance of Up-to-date Preventive & Mitigative Actions
Actions for Facilities Analysis Prior to Use as Planned/Scheduled Additional
Actions to
Prevent or
Required Factors in 452(i)(3) Documented Basis for All Required Factors in 452(i)(4) or
or Justification for Exclusion Operator Actions Credited Justification for Exclusion Mitigate
in LDS Evaluation Releases
Additional Evaluation Factors,e.g., Additional Evaluation Factors
Use of SCADA Controller Performance to
Leak Detection Thresholds Engage/Activate and Mute/ Consideration of Risk
Flow & Pressure Measures Disable LDS Features Analysis Results
Testing of Leak Detection Inspection of the Implementation of
Additional Preventive and Mitigative
Integration of Emergency Factors Affecting the Swiftness Measures Analysis:
Evaluate Spectrum of Leak Scenarios Response Procedures of Pipeline Shutdown Capability
to Determine Overall Effectiveness with LDS Indications Review
Response to Transient Related Risk Analysis
All Modes of Operation Controller Authority & Conditions Analysis of Existing Capabilities
Responsibility to Respond Analysis Documentation
Use of API-1130 for CPM Systems to Leak Indicators, Potential Effects of EFRD Justification for Assumptions
Including Shutdown Additions, Including: Basis for Decisions on Additional
LDS Availability & Reliability Valve Sequencing Preventive & Mitigative Actions
Supervisor Availability for Inadvertent Actuation Leak Detection Evaluation Study
Consideration of Shutdown Decisions Pressure Transients EFRD Risk Analysis & Effectiveness
Enhancements to Existing LDS During Valve Actuation Studies
Records Listing Risk Controls
6.06 Leak Detection: Operator Considered & Evaluation of Those
6.04 Leak Detection: Actions/Reactions 6.07 EFRD: Actions
Evaluation Factors Evaluation Factors

Note: LDS - Leak Detection System


Continual Evaluation & Assessment
Additional Guidance Overview

7.01 Periodic Evaluation 7.02 Re-assessment Intervals 7.03 Assessment Methods 7.04 Assessment Interval Variance

Methods Appropriate for Notification to Exceed Five Year


Pipeline Specific Risk Issues Reassessment Interval Inspection of Implementation for
Engineering Justifications Continual Evaluation & Assessments
Consideration of Completed
Reassessment Schedule Not 270-Day Advance
Assessment Results
to Exceed Five Years Notification Review
Periodic Evaluation of Pipeline ILI Tools Detect Corrosion & Other Methods for Reassessment Plan (Methods &
Integrity Based On All Risk Deformation Anomalies Equivalent Understanding Schedules)
Factors, Including: of P/L Condition Risk Factors
Risk Factors Listed in 452(e) Reassessment Intervals Method for Low Freq. ERW and Previous Assessment Results
Alternative Interval
Based on all Risk Factors Lap Welded Pipe Susceptible to Analysis Supporting Assessment
Information Analysis Results Technically Rigorous
and Information, Including: Seam integrity Issues Interval Selection
per 452(g) Justification
Decisions About Additional Risk Factors Listed Detect Cracks if Known Justification for Assumptions
Preventive and Mitigative in 452(e) Crack Risk Factors Unavailable Technology Notifications and Related
Actions Results of Last 180-Day Advance Documentation and Justifications
Consideration of Remedial Integrity Assessment 90-Day Notification to Use Notification
Actions Taken Information Analysis Other Technology Interim Actions to Evaluate
Consideration of all Integrity Results per 452(g) Corrosion Control Effectiveness Integrity
Assessments for Pressure Tested Segments Estimate of Completion Date
Adequate Justification
Periodic Review of
Pro-active ID of Issues that
Continuing
Reassessment Methods
Impact Schedule Assessment of
Excavations and Data Collection
Pipeline
Identification and Collection Indirect Inspection Measurements
of Adequate Data to Support Conducted in Accordance with Corrosion Defect Criteria Determination of Integrity
ECDA Pre-assessment NACE RP0502-2002, Section 4.2 Reassessment Intervals
Root Cause Identified
Additional Criteria Developed if Root
Cause Analysis Reveals Conditions Adjustment of Reassessment
ECDA Feasibility for Which ECDA is Unsuitable Intervals if Required in
Assessment Conducted Severity of Indications and Mitigation/Preclusion of Future Accordance with 452 (j) (3)
Urgency for Direct Examination External Corrosion Resulting from Continual Evaluation & Assessment
are Characterized in Accordance Significant Root Causes Process Inspection
Establish Appropriate with NACE RP0502-2002 Comprehensive Data Evaluation Performance Measures for
Sections 4.3 and 5.2 Evaluating Long-term Review
Requirements for Selection with Regard to Categorizing Repairs
Effectiveness of ECDA IM Program Documentation
of Indirect Inspection Tools and Classifying Indications
Policy Documents
Criteria to Address Reclassification Implementing Procedures
and Reprioritization of Indications Incorporation of Feedback to Baseline Assessment Plan
Application of More Restrictive Criteria for Internal Notification Demonstrate Continuous Continual Assessment Plan
ECDA Regions Identified Criteria When Conducting Initial Procedures Improvement Risk Analysis
ECDA Indirect Inspection
Alternate Methods to Assess Technical Methods for Assessment
Defects Other than External Interval Determination (e.g.,
Application of More Corrosion corrosion or crack growth models)
Restrictive Criteria When ECDA Plan/Implementation
Conducting Initial ECDA Application of More Restrictive
Pre-assessment Criteria When Conducting Initial
ECDA Direct Inspection

7.05 ECDA Pre-Assessment 7.06 ECDA Indirect Inspection 7.07 ECDA Direct Examination 7.08 ECDA Post-Assessment
Performance Measures & Program Evaluation
Additional Guidance Overview

Performance Measures &


8.01 Process Approach 8.02 Performance Metrics Program Evaluation
8.03 Communication of Results Process Inspection

Self Assessments, Type and Frequency Review


Audits, Management Preparation and Distribution IM Program Documentation
Reviews Program Implementation Metrics of Periodic Reports Policy Documents
Implementing Procedures
Scope and Timing of Threat Specific Metrics Method for Performance Metric
Periodic Evaluations Analysis & Trending
Defined Performance Goals Communication of Company's Root Cause Analysis Methodology
Performance Goals Integrity Performance and Documentation
and Objectives Benchmark Performance Actions Taken Self-Assessment or Internal Audit
Against Industry Performance Process
Roles and Responsibilities
Trending of Performance Metrics
Review and Follow- Management Follow-up to Address
up of Findings Trending of Near Misses Significant Integrity Issues
IM Program
Improvement
Rigorous and Thorough Comprehensive Written Ensure All IM Rule
Analysis of Problems and Integrity Management Program Requirements are Captured
Integrity Events
Adequate Documentation to Document Technical
Support Decisions and Actions Basis and Assumptions
ID, Tracking, and Follow-up
of Recommendations and Periodic Review of All Develop and Identify
Corrective Actions IM Program Elements Implementing Procedures Inspection of Implementation of
Performance Measurement Program
Interface Between Have Sufficient Detail and
Program Elements Specificity to Ensure Review
Communication of
Successful Implementation Performance Metrics & Data
Lessons Learned from Feedback on Change in
Root Cause Analysis Target Performance Objectives
Pipeline Conditions into Identify Roles and
Root Cause Analyses Results
IM Program Elements Responsibilities
Audits/Self Assessment Reports
Document Change Define Distribution of Corrective Action Tracking System
8.04 Root Cause Analysis
Control and Retention Key IM Documents Implementation Records for Selected
Corrective Actions
Transfer of IM Identify Management
Documentation When Involvement in IM Program
Pipeline is Sold or Acquired
Document QA/QC Process
to Ensure Accuracy and
8.05 Process Revision Consistency of IM Process
and Document Control
8.06 Process Formality

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