Offshore California Pipeline Inspection Survey Plan

The OCPIS Plan (described here and shown in the flowchart) is a process to:

• streamline regulatory process for operators;
• identify agencies' issues and concerns;
• focus deliberations to resolve concerns;
• develop a partnership among agencies to exchange information and resolve differences through coordination with operators;
• develop alternative inspection or remediation proposals as needed;
• build consensus among agencies; and
• make appropriate recommendations.

The OCPIS Plan addresses each of the following proposed actions:

• An operator's proposed survey plan or request for a waiver from existing survey requirements,
• An agency's request for a change in current survey requirements, or
• An agency's requirement for an unscheduled inspection following an offshore incident or accident.

Once an action is initiated, either by an agency or an operator, a lead agency is identified. The lead agency examines the jurisdictional issues and regulatory requirements of each affected Federal, State, and local agency and determines if a joint review or consultation is needed. If coordination is necessary, the lead agency will inform all other affected agencies of the pending action. This is documented in the Decision Checklist (1).

Using the OCPIS Checklist 1 as a guide, the lead agency gathers pertinent design, operational, inspection, repair, environmental, and other data and information from agencies' and operators' files. The evaluation of the pipeline through Checklist I is based on an analysis of eight general categories of information (containing 36 influential criteria) related to pipeline design, operation, inspection, maintenance, incident history, physical environment, and other factors.

Individual criteria on Checklist 1 are relatively weighted as "primary," "secondary," or "non-applicable," depending on how much weight (or influence) should be placed on the factor in assessing internal and external survey methods and frequencies. The purpose of the defining and weighting criteria is to provide an analytical basis for evaluating the integrity and inspection needs of offshore pipelines. However, the weight a regulator places on an individual criterion may be, in many cases, line and setting dependent regulator. The user, using sound engineering practices, must decide how much weight to place on a given criterion for a given situation or environment in reaching a decision.

The lead agency uses the Offshore California Pipeline Evaluation Analysis and Conclusions Checklist (2) to synthesize the information in Checklist I and assess the present condition of the line, the compliance history of the operator, and the potential for future pipeline failures.

Using Offshore California Pipeline Evaluation Recommendations Checklist (3) as a guide, the lead agency initiates an evaluation of the proposed action, either independently or jointly with the affected agencies, as appropriate. The agencies identify and attempt to resolve concerns relating to the pipeline evaluation, the proposed action, or an alternative recommended action(s) through coordination with all parties including the operator. The agencies work towards achieving a consensus on the proposed action, if possible, and issue either joint or independent recommendations to their respective management to approve or deny the proposed action (i.e. Plan or waiver request) or to require an alternate inspection or remediation plan. The operator is subsequently notified in writing of the decision(s).

The OCPIS Plan is a consensus-based, decisionmaking process intended to provide user agencies with an analytical framework for assessing the present condition and inspection needs of offshore pipelines. Implementation of the OCPIS Plan permits pipeline operators to develop inspection strategies that are tailored to the needs of individual lines based on the actual conditions of the pipelines. Requiring operators to conduct the most beneficial surveys based on the actual condition of the line will improve pipeline safety and reduce the risk of failure while affording industry an opportunity to reduce survey costs as a benefit of diligent and innovative inspection and maintenance.