# Presentation: 134975

## OPS Observations, Expectations, and Concerns

**Zach Barrett (OPS)**
**Direct Assessment Workshop **
**November 4, 2003**

**Notes:**
This Presentation is Designed to Provide some Federal Insight Regarding Our Understanding of the Current Status of the Direct Assessment Methodology.

Direct Assessment is a Developing Assessment Technology Designed to Complement Inline Inspection and Pressure Testing. 

 Direct Assessment was Developed to Bridge a Gap for  Pipelines that can not be Assessed by Other Means or for Pipelines which Direct Assessment Provides an Improved Assessment Methodology.

## Observations

**Not Always Practical To Inline Inspect**
**Small Diameter Lines **
**Telescoping Lines (Storage Fields)**
**Short Radius Bends**
**Crossover Lines**
**Adverse Flow Conditions**

**Notes:**
Inline Inspection is not Applicable to All Pipelines Usually Due to Design Considerations.

Like Other Assessment Technologies Inline Assessment does not Identify All Questionable Features All the Time.

## Observations

**Not Always Practical To Pressure Test**
**Supply Concerns **
**Water Availability and Disposal**
**Internal Corrosion Concerns**
**No Quantification of Future Corrosion Risk**

**Notes:**
Pressure Testing is Not Always an Option for Assessment
Pressure Testing Does Not Provide Data for Future Analysis – Pass or Fail Test
Best Suited for Crack and Longitudinal Seam Assessment & Remediation

## The Landscape is Changing

**Individual Cathodic Protection and Coating Surveys**
**Long History of Operator Use**
**Evolving into “Direct Assessment”**
**Formalized Process**
**Integration of Data**

**Notes:**
There Have Been Numerous Public Meetings to Review the Proposed IM Rule and its Direct Assessment Provisions.

Direct Assessment Will Improve Pipeline Safety

## The Landscape is Changing

**Pipeline Safety Improvement Act of 2002**
**Includes Provisions for Direct Assessment**
**Pending Gas Integrity Management Rule**
** ****Includes Direct Assessment**

**Notes:**
The Pipeline Safety Improvement Act within Section 23 requires that OPS “....issue regulations prescribing standards for inspection of a pipeline facility by Direct Assessment.”

## The Landscape is Changing

**NACE Developing DA Recommended Practices**
**RP0502-2002 External Corrosion Final**
**Internal Corrosion Dry/Wet Gas**
**Stress Corrosion Cracking **

**Notes:**
The ECDA Standard Was Finalized October 2002.

ICDA standard for dry gas is being developed (ballot was due August 29th) in task group 293.

SCCDA standard is under development (about a year behind the internal corrosion standard).

More on These in Later Sessions.

## OPS Concerns

**Validation of Direct Assessment Methodology**
**Are Standards Appropriate**
**Will Direct Assessment Identify Threats to Pipeline Integrity**
**Repeatability of Process and Results**

## OPS Concerns

**Validation of Direct Assessment Methodology**
**Establishment Excavation Criteria**
**Reassessment Interval Justification **

## OPS Concerns

**Indirect Assessment Tool Limitations not well Defined (Probability of Detection)**
**Important for Tool Selection**
**Critical for Setting Reassessment Interval**
**Needs Field Validation**

## OPS Expectations

**Validation through Direct Assessment Workgroup Demonstrations**
**Standard Applicability**
**Strengths and Limitations of the Methodology**
**Improvements to Pipeline Integrity Resulting from Direct Assessment**

## OPS Concerns

**Consistency in Application of Assessments**
**Critical for Repeatability of Results**
**Successful Monitoring of Non-excavated Indications**

## OPS Expectations

**Development of Detailed Process and Documentation for:**
**Direct Assessment Approach**
**Staff & Contractor Qualifications**
**Bases for Key Decisions & Criteria**
**Employee & Contractor Roles**

**Notes:**
OPS Believes that Process Development is Key to the Success of Direct Assessment 

This is a Theme that will be Repeated Though Out the Presentation

## OPS Concerns

**Data Availability**
**DA Requires Complete and Reliable Data**
**Data Must Be Acquired Where Lacking**
**May Result in Additional Direct Examinations**

**Notes:**
Data Availability and the Quality of that Data can be Problematic for Existing Pipelines as Records were not always kept.

## OPS Concerns

**Existence of Mature Data Management Processes**
**Acquire, Store, Retrieve**
**Data Quality - Verification **
**Crucial to Effective Data Integration/Analysis**

**Notes:**
Pipeline Companies Have Been Conducting Cathodic Protection and Coating Surveys for some time.  

Direct Assessment takes that technology a step further by requiring integration of data about the Pipeline and its surroundings and their history.

Pipeline Companies have not always had Documentation and Record Keeping Capabilities necessary to perform a good data integration.

## OPS Expectations

**Development of Effective Data Management System**
**Processes and Procedures Key**
**Data Collection, Storage, Retrieval **
**Data Integration **
**Data Quality/Control**

**Notes:**
Development of Detailed Processes and Procedures are Key to Success

Includes Data Collection, Storage, and Retrieval Elements

As Previously Discussed Data Integration Key Component

Data/Information must be of good Quality to provide Effective Bases for Analysis

## OPS Concerns

**Proper NDT Methods for Direct Assessment  **
**Important for Effective Data Integration/Analysis**
**Crucial for Identifying Proper Preventive or Mitigative Actions**
**Key to Effective Reassessment Interval**

## OPS Expectations

**Development of Effective DA Process and Procedures**
**Identifies Integrity Threat **
**Conservative in Consideration of Full Range of Integrity Threats**
**Provides Quality Data for Future Analysis**

**Notes:**
Again Detailed Processes and Procedures are Key to a Successful Non-Destructive Testing Program.

Integrity Threats May not Always be Apparent without Good Testing Protocols

Can’t Address Threats if they are not Properly Identified

Provides Good Quality Data for Future Analysis

## OPS Concerns

**Timeliness of Standard Development**
**Key to Ensuring Quality and Consistency**
**Developing for:**
**ICDA – Wet/Dry Still Under Development**
**SCCDA – Still Under Development**

**Notes:**
Timeliness of Standard Development is Important to the Success of the Direct Assessment Program.

Standards Provide Implementation Consistency and Set Compliance Minimums

Standards Provide Methodology Applicability Criteria  

## OPS Expectations

**Standard Development**
**Should Follow ECDA Path for Evaluation/Validation**
**Update Standards as Experience Demands **
**Provide Detailed Guidance Where Appropriate**

**Notes:**
OPS believes Detailed Standards are Key to the Improvement of Pipeline Safety

Success will depend on the Resolve of Standards Development Groups for Continuous Improvement and Incorporation of Lessons Learned.

Updates should keep pace with Technological Improvements 

## Successful Programs

**Establish Detailed Procedures for All Activities **
**Data Collection/Management**
**Feasibility Determinations**
**Definition of Regions**
**Indirect Inspection**

**Notes:**
Again OPS believes the Key to Integrity Management is the Development of Effective Processes and Procedures.

## Successful Programs

**Establish Detailed Procedures for All Activities **
**Data Integration & Risk Analysis**
**Direct Examination**
**Post-Assessment**

## Successful Programs

**Procedures Address**
**Responsibilities**
**Task Identification**
**How & When Task is Accomplished**
**Communication of Task Results**
**Records & Documentation**

**Notes:**
Procedures must identify who is responsible for the completion of identified task

## Successful Programs

**Demonstrate Effectiveness**
**Aggressive Excavation Criteria **
**Data Integration**
**Comparisons with Excavation Findings**
**Re-assessment Results**

## Successful Programs

**Documentation**
**Identifies and Provides Justification for Assumptions**
**Evidences Compliance with Gas IM Rule**
**Provides Detailed Explanation When Standards not Followed**
**Details are Important**

## Path Forward

**Continued Participation in DA Demonstration Projects**
**Continued Support for Standards Development**
**Improve from Lessons Learned**