Blue Hawk-PSM Mechanical Integrity & COGCC 609 Compliance Case Study
February 16, 2021
HCA & MCA Support
March 15, 2021

Problem
A small private equity backed operator needed support on annual integrity management and DOT compliance tasks but did not have the resources in house to complete these. Our client does not have the budget to hire a full-time resource and their current team already has a full workload on their plate.

Approach and Solution
At Integrity EPC, we dedicated a resource to be our client’s main point of contact and extension of our client’s team to make sure they meet all annual requirements of PHMSA. Not only do they have access to a main SME contact on this topic, but our client also has access to a team of experts to help them make sure they complete compliance tasks within a cost effective budget.

Execution
The tasks below were performed by an Integrity EPC team of experts on behalf of our client:

  1. Perform HCA Identification
    1. If gas, determine class location and find identified sites
    2. If liquid, determine spill plumes and overlay with state and federal HCA polygons
  2. Develop a baseline assessment plan (BAP)
    1. Build BAP and deliver for review
    2. Receive comments, finalize and deliver final version
  3. Run a risk evaluation
    1. Build a risk algorithm with operator SME personnel
    2. Work with client’s personnel to fill in areas with existing data, determine default values, research possible other available digital sources, update data, run risk, review and finalize
  4. Conduct a preventative and mitigative measures (PM&M) meeting
    1. Review risk results, BAP, IMP and determine if there are any needs to reduce risk in high risk situations and document results for review in PM&M meeting
  5. Develop plan for integration of new data for future improvement
    1. Annual integrity work involves incorporation of all possible data for integration and to understand possible areas of future improvement for plan development, including data from regularly scheduled field tasks, new as-builts, and assessments.
  6. Conduct an annual evaluation of the integrity program
    1. Review IMP and O&M annual evaluation
    2. Determine performance measures and build spreadsheet identifying these measures
    3. Review weather related events which may cause field evaluation
  7. Perform annual required OQ field covered tasks
    1. ROW Patrols
    2. Leak Surveys
    3. CP Surveys
    4. Rectifier inspections
    5. Class location verification

Solution
By dedicating our team of experts, we were able to meet all requirements for PHMSA by working closely with our client as if we were a part of their team. At Integrity EPC, we understand the strain that PHMSA’s requirements puts on small operators, which is why we strive to be a one stop shop for our Clients.

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