Lessons Learned in MAOP Validation Process

Report
Lessons Learned in MAOP
Validation Process
August 21, 2012
Chris Foley
Vice President
RCP Inc.
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
www.rcp.com
Professional Engineering Consulting Firm
• Pipeline Regulatory Compliance & Engineering
– Asset / Compliance Management Software Applications
– Pipeline Integrity Assessment Support
– Acquisition Due Diligence
– Long-Term Pipeline Compliance / Engineering Staff
Support
– Hydrotest Planning & Certification
• MAOP Services
– MAOP Studies (as a service)
– Turnkey MAOP Validation Services
– MAOP Validation Software
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
www.rcp.com
•
•
•
•
Comprehensive Tool
MAOP calculator tool
– Analysis as a service & available to operators via license agreement
– Comprehensive
• Gas/Liquid, Onshore/Offshore, Steel/Plastic, Federal/State/LOI’s
Identifies potential MAOP deficiencies
– Data gaps
– Source documentation (gaps and/or questionable quality)
– Differences in calculated MAOP vs. established MAOP
Links source documents to data (Traceability)
– Creates a traceable association between data and source documentation
Accepts data sets in various formats (.xls, PODS, APDM)
– Historical documentation / manual edits to existing data sets
– .xls templates (RCP pre-configured or operator/3rd party developed)
• Customizable to fit operator terminology or other specific needs
– GIS data models (impartial to type or version)
• Linear data (stationing/measurement)
• Non-linear (distribution networks) tolerant
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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Turnkey MAOP Validation Process
• Preparation
• Pilot
• Execution
• Resolve Discrepancies
• Prioritize / Mitigate Problem Segments
• Ongoing Sustainable Process
Preparation
• Evaluate current MAOP process
• Determine document quality and grading standards
– Single vs. complimentary document types
• Deliverables & sustainability goals
– Source document gaps, MAOP calculation variances, correct GIS data
– Link source documents to MAOP calculated variables
– Map process flow & update procedures
• Imaging
– Electronic library
• Data repository
– MAOP calculator / Reporting capabilities (slice & dice)
• Location for document review
– Main office, field office, off-site
• # of people and their roles
– Schedule, miles of pipeline, record quantity, record quality
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
www.rcp.com
Pilot
• Small grouping
– System location / type / pre or post regulation
– Source document type
• Hydrotest, Alignment sheets
• Source Documentation
– One touch philosophy
– Organize / Index
• Test and improve MAOP validation process
design
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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MAOP Execution Process Flow Diagram
Source Documents
RCP Document Review & Data Extraction
Capture MAOP Data to MaxOp®
Source Document Data
Set
Operator SME Review and Gap Closure
Attach Cover Sheet and Return to Box
Station Corrections
QC Box (Revise as Necessary)
Source Document
Imaging to Electronic
Library
Pipeline Identification
Flag Issues That Require Operator
Feedback
Combined MAOP Data
Set (Raw)
GIS Data (PODS, APDM, etc.)
“Smart” Segmentation
Update GIS data
Assign Default Values
Resolve Data Gaps
Validated MAOP Data Set
Source Document
Electronic Library
“Calculator Ready”
MAOP Data Set
Run MaxOp® Calculator
MAOP Calculation Results
Iterative Process Improvement
Established MAOP vs. Calculated MAOP
Research & fill missing data gaps
Validated MAOP Segments
Improve document quality, if possible
Non-Validated MAOP Segments
Update data sets with better data
Source Document Grading Profile
Re-run MAOP analysis & compare results
vs. established MAOP
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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Document Review
• Source document data posted to MaxOp cover sheet
• Unique ID assigned to each source document / folder / file
• Bar code creates a traceable link from the data back to the
source document (scanned image)
TM
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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Quality Control Challenges
• Historical documentation
– Stationing listed (if any) may not match current GIS standards
– Unsure if the document is the most current for that segment
• Ex. HQ alignment sheets vs. redlines @ field offices
– Filing structure isn’t conducive to limiting research to Class 3 & 4 and HCA’s
• Organized by WO / AFE#
• Merging of GIS & Historical documentation
– What is the source of the electronic data (GIS, risk, .xls, ILI, etc.)?
– Historical takes precedence unless otherwise determined by operator (PHMSA
ADB)
– Terminology of documentation not matching GIS terminology
• Ex. line identification – Line #2 South TX Jct. vs. Route Code 12345
• Expertise of Document Review & QC Personnel
– Natural trade-off’s between quantity, speed, quality & cost
– Steep learning curve, must be willing to invest in strong training & QC process
– Document review can be tedious; must let those who have mastered this
process to promote up to QC / other roles
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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Discrepancy Resolution
• PHMSA ADB 12-06
– Annual report due 3-15-2013
– Class 3 & 4 and HCAs in Class 1 & 2 (Annual Report NOPR?)
• Gaps in source documentation
– Poor quality document grades
• Calculated MAOP < Established MAOP
• Are there newer or higher quality source documents
elsewhere (“Complimentary Documents”)?
• Linear reference & stationing issues
• Non-linear (distribution system) replacement projects
– Old source document replaced with new one
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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Identify Potential
MAOP Deficiencies
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Prioritize & Mitigate “Problem Segments”
• What is PHMSA’s next step after the 2013
annual report?
– PHMSA Annual Report Revisions NOPR (4/13/2012)
• All transmission mileage validated (not just class 3&4 and class 1&2 HCA)
• Deadline March 15, 2013 (not July 3, 2013 per PHMSA reauthorization
bill)
– Industry Comments
• Hydrotest or other?
– Anyone want to go in w/me to buy/build hydrotest company?!?!
• Schedule and priority?
– Likely some risk-based approach
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
www.rcp.com
NOPR Annual Report Section Q
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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NOPR Annual Report Section R
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
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Sustainability
Work / Asset Management Systems
• Link source documents to MAOP data
– GIS (PODS, APDM, other)
– MAOP Data Books (hard copy vs. electronic)
• Develop/improve MAOP procedures
– Data capture
– Data repository
– Responsibilities
• Don’t want to repeat this effort!
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
www.rcp.com
Questions?
Chris Foley
RCP Inc.
Vice President
[email protected]
(713) 655-8080
PROFESSIONAL ENGINEERS. REGULATORY EXPERTS. TRUSTED PARTNERS.
www.rcp.com

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