Despite all the attention that Integrity Management Plans have gotten, there is an ongoing problem which needs to be overcome before IMP is fully effective. EMS Group looks at the challenge of documenting repair and remediation activities.

Vince Lombardi, the well-known coach of the Green Bay Packers, said, “If winning isn’t everything, why do they keep score?”

So who’s keeping score when it comes to your pipeline’s Integrity Management Program (IMP)? “They” are: the public, the regulators – they’re all keeping score. Because if your pipeline leaks, you are de facto not in compliance with your plan, no matter how good your IMP is.

Look at your situation another way. Pretend that the only documents you and the American public read are the 2006 Liquid Pipeline Accident, Natural Gas Transmission Incident, and Natural Gas Distribution Incident Summaries issued by the US Office of Pipeline Safety last month.

You might feel good about the state of pipeline integrity management programs. Compared with 2005, the number of accidents and the dollar value of property damage were reduced by big percentages.

In real life, the public in 2006 read about the “largest spill of crude oil on the northern slope” or “pipeline accident leads to proposed safety bill”. That bill was signed into law on the last working day of this past December: The Pipeline Inspection, Protection, Enforcement and Safety Act of 2006 extends the US Department of Transportation’s oversight to include oil and gas pipelines operating at low pressures. Regulators said that corrosion management practices on the
low-pressure lines at a particular field failed to meet minimum industry standards.

It’s one more law to reinforce multiple regulations that operators are already trying to follow. Again and again, we have learned that the major result of public perception is always guilt until innocence is proven. (In civil litigation, sometimes that isn’t even enough.)

What’s being done right?
Operators have developed and implemented written integrity management plans that help them identify threats, both existing and of potential future importance. They are working to recognize and implement appropriate measures to mitigate risks – and they report performance measures to our regulators. We would say that the accident and incident summaries prove that regulations are being followed, mainly.

The practical aspects of pipeline integrity programs, the components of a successful IMP, and details on how to detect problems that require immediate attention, are already known. Smart pig inspections, external corrosion direct assessments (ECDA), internal corrosion direct assessments (ICDA), and geometry tool assessments of minor mechanical damage already exist. Anomalies are found and repairs are scheduled.

And an ounce of prevention is worth a pound of cure: proper repairs can be expedient and relatively inexpensive – the kinds of repairs that consistently increased system reliability and integrity in the past few years.

If you don’t write it down, it never happened
What is missing from our industry’s overall “best practices” picture is documentation. Did your repair crew write everything down? Is the find-fix-test process properly documented? It’s a crucial, absolutely-must-have component of a comprehensive IMP. Far too often, the writing-down part doesn’t get done – especially if sub-par contractors are used in the repair.

Your plan’s requirements are likely to be quite clear. For example, when a magnetic anomaly shows up, you must indicate precisely where and what it is.

Confirmation digs compare what’s actually there versus what the pig says is there. The anomaly must be characterized. You must not only find the corrosion anomaly or mechanically damaged location, you must fix it. What precisely did the repair entail? What about the type of coating? Is it fusion bonded epoxy? Coal tar? Has it been properly applied? How about your post-repair test procedures? Have they been recorded and forwarded to the appropriate management team? Results of integrity tests must be tracked, documented, and repeated at prescribed intervals.

In other words, did your repair crew fully document the steps outlined in your own plan? Because if they didn’t, you have not only violated procedure, you have undercut your ability to prove – in a court of law – that you’ve followed your own IMP plan to the letter.

We believe you should always have the knowledge in place to execute the existing plan properly. No one wants the accident to happen in the first place. Remember: when your pipeline fails, your integrity management plan didn’t work. Why? Everyone is going to be asking you this ugly question.

Your answers: “Yes, we had a failure. We were not negligent. We did everything according to plan. We followed the plan. And we can prove it.” This is where the documentation is crucial.

Analysis can only be done properly if the diggers collect the data. Think of it as a form of institutional memory. If you don’t write it down, it never happened.

An “all the time” imperative
Our entire industry is moving into administration: paperwork drives operations, rather than the reverse. We believe this is a key issue, because of our strong reputation as a qualified high consequence area (HCA) contractor.

Through written assessment, EMS Group recommends targeting operator qualification and training requirements on several levels – “best practices” which include documentation for every action.

EMS Group ensures that company-wide and pipeline-specific procedures are documented every step of the way, every time. Our scope of work in IMP-focused pipeline evaluations, repairs and tests goes beyond ordinary maintenance. That’s part of an important message to the pipeline industry: We suggest that the best defense is a good offense. Ongoing documentation is how to take the Integrity Management offensive.

Vice Lombardi also said, “Winning is not a sometime thing; it’s an all the time thing. You don’t win once in a while; you don’t do things right once in a while; you do them right all the time.