Facilities Integrity Management Program Recommended Practice, 1st Edition May 2013

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1 Facilities Integrity Management Program Recommended Practice, 1st Edition May 2013

2 Notice of Copyright Copyright 2013 Canadian Energy Pipeline Association (CEPA). All rights reserved. Canadian Energy Pipeline Association and the CEPA logo are trademarks and/or registered trademarks of Canadian Energy Pipeline Association. The trademarks or service marks of all other products or services mentioned in this document are identified respectively. Disclaimer of Liability The Canadian Energy Pipeline Association (CEPA) is a voluntary, non-profit industry association representing major Canadian transmission pipeline companies. The Facilities Integrity Management Program Recommended Practices (hereafter referred to as the Practices ) were prepared and made public in effort to improve industry performance and communication of expectations to stakeholders. Use of these Practices described herein is wholly voluntary. The Practices described are not to be considered industry standards and no representation as such is made. It is the responsibility of each pipeline company, or other user of these Practices, to implement practices to ensure the safe operation of assets. While reasonable efforts have been made by CEPA to assure the accuracy and reliability of the information contained in these Practices, CEPA makes no warranty, representation or guarantee, express or implied, in conjunction with the publication of these Practices as to the accuracy or reliability of these Practices. CEPA expressly disclaims any liability or responsibility, whether in contract, tort or otherwise and whether based on negligence or otherwise, for loss or damage of any kind, whether direct or consequential, resulting from the use of these Practices. These Practices are set out for informational purposes only. References to trade names or specific commercial products, commodities, services or equipment constitutes neither an endorsement nor censure by CEPA of any specific product, commodity, service or equipment. The CEPA Facilities Integrity Management Program Recommended Practices are intended to be considered as a whole, and users are cautioned to avoid the use of individual chapters without regard for the entire Practices. Suite 200, rd St. SW Calgary, Alberta T2P 3E6 Tel: Fax: CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 2 of 57

3 Table of Contents Table of Contents... 3 List of Tables... 5 List of Figures Definition of Terms Introduction Importance of Terminology Revisions to this Recommended Practice Background and Philosophy Framework Scope Scope of Facilities and Equipment Scope of Processes and Mechanisms Prioritization of Equipment Types and Processes Corporate Policies, Goals, Objectives and Organization Policies, Goals and Objectives Organization Performance Indicators and Targets Description of Facilities Records Facility Information FIMP Information Change Management General Change Management Process Features Competency and Training Establish Role Requirements Conduct Gap Analysis Execute Training Plan Undertake Follow-Up Discussion Hazard Identification and Control Choose Hazard Identification Method Hazard Identification Exercise Review Potential Consequences Estimate Likelihood of Consequences Conduct an Initial Assessment of Significance CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 3 of 57

4 9.6. Determine Risk Assessment Needs Risk Assessment Risk Analysis Data Availability Organizational Maturity Goal of the Analysis Magnitude of the Decision Risk Evaluation Risk Refinement Risk Reduction Evaluation Options for Reducing Uncertainty, Frequency or Consequences of Incidents Monitoring and Inspection Mitigation Planning and Executing Plan and Execute Activities Evaluate Repair Repair Identification Repair Execution Continual Improvement Process Characteristics Specific Considerations Incident Investigations A1. Illustrative Example of Equipment Classification Method A2. Sample Performance Indicators A3. Guidance Regarding FIMP Documentation A4. List of Hazards for Consideration A5. Monitoring and Inspection A6. Reference Documents CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 4 of 57

5 List of Tables Table 1: Comparison of Facility and Pipe IM Programs Table 2: Potential Basis for Initial Prioritization of FIMP Scope Table 3: Key FIMP Roles and Responsibilities for Consideration Table 4: Two Types of Performance Indicators Table 5: Considerations in Establishing Performance Targets Table 6: Descriptive Parameters for FIMP Pipeline Systems Table 7: Recommendations for Data Capture for FIMP Assets Table 8: Potential Triggers for Change Management Process Table 9: Minimum Features of Change Management Process Table 10: Considerations in Establishing Competency Requirements Table 11: Resources for Determining Training Needs Table 12: Categorization of Qualification Gaps Table 13: Mechanisms for Mitigating Qualification Gaps Table 14: Objectives of Follow-Up Employee Discussion Table 15: Additional Guidance for Establishing Significance of Risk Table 16: Parameters for Risk Refinement Table 17: Approaches for Managing Risk Table 18: Considerations for Selecting Monitoring & Inspection Activities Table 19: Mitigation Activity Types Table 20: Considerations for Determining Acceptable Mitigation Table 21: Considerations for the Review of Current Assumptions Table 22: Considerations for Program Execution Table 23: Considerations for Program Review Table 24: Considerations for Addressing Identified Anomalies Table 25: Considerations for Executing Corrective Actions Table 26: Elements of Continual Improvement Process Table 27: FIMP Documentation and Reference Guideline Table 28: Sample List of Equipment Specific Considerations Table 29: Sample List of Monitoring and Inspection Goals Table 30: Industry Published Guidance Documents Table 31: Additional Guidance from Other References CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 5 of 57

6 List of Figures Figure 1: Relationship of FIMP to Existing Corporate Systems Figure 2: Facility Integrity Management Program Process Figure 3: Sample Equipment Classification High Level Figure 4: Scope of Processes and Mechanisms for Consideration in FIMP Figure 5: Translation of Corporate Priorities to Appropriate Integrity Activities Figure 6: Consequence Categories for Consideration Figure 7: Competency and Training Process Figure 8: Hazard Identification and Control Process Figure 9: Critical Factors in Selecting a Risk Assessment Approach Figure 10: Process for Planning and Executing Figure 11: Sample Equipment Classification Pipeline Breakdown Figure 12: Sample Equipment Classification Meter Breakdown Figure 13: Sample Equipment Classification Station Breakdown Figure 14: Sample Equipment Classification Storage Breakdown Figure 15: Sample Equipment Classification Common Systems & Facilities Breakdown CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 6 of 57

7 1. Definition of Terms The following definitions apply in this document. Asset: Cathodic Protection: Consequence: Engineering Assessment: Equipment: Facilities Integrity Management Program: Facility: Hazard: Integrity: A generic reference to an arbitrary grouping of components, equipment or facilities where groupings are usually defined based on rules specific to each Operating Company. A technique to prevent the corrosion of a metal surface by making that surface the cathode of an electrochemical cell. Describes the result of an accidental event. The consequence is normally evaluated for human safety, environmental impact and economic loss. A detailed technical analysis, as may be required from time to time, to assess or analyze whether a piece of equipment, or grouping of equipment, is suitable for service in its intended purpose or application. A grouping of individual components designed and assembled to serve and engineering purpose (e.g., air compressor). A documented program, specific to the facilities portion of a pipeline system, that identifies the practices used by the Operating Company to ensure safe, environmentally responsible, and reliable service. A grouping of individual pieces of equipment designed and constructed to facilitate a larger (engineering) process (e.g., compressor station). A condition or practice with the potential to cause an event that could result in harm to people, the environment, the company s reputation, business or operation / integrity of its facilities. Used in the context of managing pipeline systems, a general understanding or definition of integrity has to do with quality; that a mechanical component meets or exceeds CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 7 of 57

8 design specifications for an intended purpose or application 1. Integrity Management Program Mitigation Operating Company: Pipeline: Pipeline Integrity Management Program Pipeline System: Risk: A documented program that specifies the practices used by the Operating Company to ensure the safe, environmentally responsible, and reliable service of a pipeline system. 2 Activities to manage the risk exposure of a particular pipeline system or its individual components. Mitigation activities are broad ranging and are specific to the context (i.e., the type of equipment, its current state, and operating conditions) 3. Mitigation may be in the form of threat mitigation or consequence mitigation as discussed in Section 11. The individual, partnership, corporation, or other entity that operates the pipeline system or an individual facility. Those items through which oil or gas industry fluids are conveyed, including pipe, components, and any appurtenances attached thereto, up to and including the isolating valves used at stations and other facilities 4. A documented program, specific to pipelines, that specifies the practices used by the Operating Company to ensure the safe, environmentally responsible, and reliable service of a pipeline system. 5 Pipelines, stations, and other facilities required for the measurement, processing, storage, gathering, transportation, and distribution of oil or gas industry fluids. 6 Strictly defined as the probability of an event or occurrence multiplied by the consequence of that event as per Equation (1). A detailed discussion appears in Section Baker, H.F., Mechanical Reliability through Mechanical Integrity, Proceedings of 2011 API Inspection Summit and Expo, Galveston Texas, January CSA Z662 Oil & Gas Pipeline Systems (CSA Z662-11) 3 Desjardins, G. & Sahney, R., Encyclopedic Dictionary of Pipeline Integrity, Clarion Technical Publishers, Houston, Texas, February CSA Z662 Oil & Gas Pipeline Systems (CSA Z662-11) 5 CSA Z662 Oil & Gas Pipeline Systems (CSA Z662-11) 6 CSA Z662 Oil & Gas Pipeline Systems (CSA Z662-11) CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 8 of 57

9 Risk Assessment: Service Fluid: Station: The detailed study undertaken to establish the risk associated with a specific piece of equipment, facility or pipeline system. A detailed discussion appears in Section 10. The fluid contained, for the purpose of transportation, in an in-service pipeline system 7. A facility used primarily to alter the pressure in a pipeline system, including a) piping; b) auxiliary devices such as pumps / compressors, driver units, control instruments, enclosures, ventilating equipment, and utilities; and c) any associated buildings other than residences. 2. Introduction 2.1. Importance of Terminology Part of the objective of this Recommended Practice is to provide clarity and consistency regarding terminology. As such, the reader is encouraged to review Section 1 of this document with particular attention to the following terms and their usage: Facilities Integrity Management Program; Integrity; Integrity Management Program; Mitigation; Pipeline Integrity Management Program; Pipeline; and Pipeline System. These particular terms are important to understanding the scope and intent of the discussions throughout this recommended practice Revisions to this Recommended Practice This Recommended Practice has been developed by CEPA s Pipeline Integrity Working Group (PIWG). It will continue to evolve as new advances and opportunities for improvement are recognized during its use by CEPA member companies and from periodic reviews as deemed necessary by CEPA and/or the PIWG. 7 CSA Z662 Oil & Gas Pipeline Systems (CSA Z662 latest edition) CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 9 of 57

10 2.3. Background and Philosophy This recommended practice provides guidelines for developing, documenting, and implementing a Facilities Integrity Management Program (FIMP) for transmission pipeline related facilities. Specific guidance is provided regarding the development of goals and objectives, as well as supporting programs and processes, to effectively maintain facilities integrity. This document puts forth the recommendations to be included in an Operating Company s FIMP based on leading industry practice and building on guidelines established in CSA Z662 Annex N. The objective of a FIMP is to provide Operating Companies with a formalized mechanism to maintain the integrity of the managed assets that demonstrates a commitment to protect the health and safety of the general public, employees and the environment. Further, the guidelines are intended to allow flexibility in the development of a FIMP and to remain relevant to the Operating Company s context while identifying leading practices in the area. The FIMP is not intended to duplicate any systems, processes or information that may already exist. Thus, this recommended practice is structured to allow Operating Companies the ability to acknowledge any pre-existing body of work that have been incorporated into their respective processes or programs. It should be noted that an integrity management program for facilities is, by definition, quite different from an integrity management program (IMP) for a pipeline. These differences are driven by the nature of the assets to be managed (scope) and the resulting objectives (program purpose) for those assets as well as vastly differing life cycles. These key differences are identified and summarized in Table 1. Table 1: Comparison of Facility and Pipe IM Programs Parameter IMP FIMP Scope Assets relatively uniform (i.e., pipeline(s) Disparate asset types. of varying grades, wall thicknesses and diameters). Program Goal The safe, environmentally responsible, and reliable service of pipeline(s) by working towards minimizing loss of service fluid containment. The safe, environmentally responsible, and reliable service of all pipeline system facilities, exclusive of pipelines, by striving to ensure control and containment of service fluids and Equipment meets or exceeds design life given its intended purpose and actual operating conditions. Asset Life Cycle Long lifecycle. Life cycles vary significantly and Assets with long life cycles often contain numerous components with short lifecycles. Each Operating Company will select processes appropriate for its situation, associated with a FIMP, and separate these from its Pipeline CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 10 of 57

11 Facilities Integrity Management Program (FIMP) Integrity Management programs. Where relevant, existing reliability programs and prescribed equipment management programs can be referenced by the FIMP and may continue to exist with the appropriate linkages to FIMP processes. More specifically, and as illustrated in Figure 1, the FIMP is intended to encompass all of an Operating Company s facilities with the exception of the pipeline (which would be covered by a Pipeline Integrity Management Program). However, it is fully expected that Operating Companies would then refer to any existing programs, processes and databases, where appropriate, within the FIMP document. In effect, the FIMP is an umbrella document referring to pre-existing material for the vast majority of facilities that may already be managed through existing systems leaving only a limited scope of facilities and / or equipment (if any) to be formally managed through the FIMP process itself. Incorporates existing programs by reference Incorporates existing processes by reference Incorporates existing data / documentation by reference Assets directly managed through FIMP document Figure 1: Relationship of FIMP to Existing Corporate Systems 2.4. Framework This document builds on the framework outlined in CSA Z662 Annex N as a basis for providing guidance on developing a FIMP. Specifically, the following major elements detailed in Figure N1 (reproduced here as Figure 2) of CSA Z662 Annex N (2011 Edition) are described and discussed in the context of FIMP development: a) Section 3: FIMP Scope; b) Section 4: Corporate Policies, Objectives and Organization; c) Section 5: Description of Facilities; d) Section 6: Program Records; e) Section 7: Change Management; f) Section 8: Competency and Training; g) Section 9: Hazard Identification and Control; h) Section 10: Risk Assessment; i) Section 11: Options for Reducing Uncertainty, Frequencies and Consequences; j) Section 12: FIMP Planning and Execution; k) Section 13: Repair; l) Section 14: Continual Improvement; and m) Section 15: Incident Investigations. CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 11 of 57

12 Section 3: Integrity management program scope Section 4: Corporate policies, objectives, and organization Section 5: Description of pipeline systems Section 6 to 8: Integrity management program records, change management, competency and training Identify potential hazards Section 15: Incident Investigations No Can the hazard lead to significant consequences? Section 9: Hazard Identification and Control Yes No Perform risk assessment? Yes Risk assessment Select control measure(s) for risk reduction Yes Section 10: Risk Assessment Section 11: Options for Reducing Uncertainty, Frequency or Consequences of Incidents No Choose to refine risk analysis? Yes Is risk significant? No Select control measure(s) for risk reduction Establish, plan, and schedule activities Section 12 & 13: Planning, Executing & Repair Implement activities Section 14: Continual Improvement Review and evaluate program control methods and risk management cycle No Changes? Yes Figure 2: Facility Integrity Management Program Process 8 8 Adapted from CSA Z662 Oil & Gas Pipeline Systems (CSA Z662-11) Figure N1 CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 12 of 57

13 3. Scope FIMP documentation must clearly define the scope of facilities and equipment (and associated processes) managed directly by the FIMP document versus the assets managed through other systems and documents (as per Figure 1). Where equipment is managed through other systems and documents, the FIMP should clearly refer to the relevant documentation. Additional guidance appears in the remainder of this Section Scope of Facilities and Equipment This document uses a definition of Facilities and Equipment derived from usage of the terms: Pipeline System and Pipeline in CSA Z662 (2011 Edition). That is, a Facilities Integrity Management Program (FIMP) is intended to address all components of a Pipeline System, with the exclusion of the Pipeline itself (to be covered by a Pipeline Integrity Management Program). Any asset types covered by new or existing programs, that are supportive of the objectives and goals of the FIMP, may be incorporated into the FIMP by reference. Further, given the nature of the FIMP and the need to address a wide variety of asset and equipment types, the Operating Company should use a systematic and consistent classification method as a mechanism for addressing all asset classes. The classification method may be based on a number of approaches one of the most common examples is the use of an equipment hierarchy. Such structures are typically used in the corporate Computerized Maintenance Management System (CMMS). In the absence of a pre-existing classification methodology, the systems (or function-based) approach shown in Figure 3 could be adapted. CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 13 of 57

14 Pipeline System Stations Meter Station Pipeline (significant elements managed through parallel IMP) Storage Common Systems and Equipment Figure 3: Sample Equipment Classification High Level Additional levels of detail for such an Equipment Classification Hierarchy, while not exhaustive, are illustrated in Appendix A1. Further details can be developed based on the hierarchy as needed and appropriate for the facility Scope of Processes and Mechanisms A FIMP shall be documented and consider the methods for collecting, integrating, and analyzing information related to the processes and mechanisms identified in Figure 4, as appropriate for the type of facility and the operating company s operations. The approach should be consistent with Figure 2 and as holistic as possible that is, incorporate the entire lifecycle to the extent possible. Thus, the process is fundamentally a variant of the Plan-Do-Check-Act cycle developed by Deming 9. One of the key implications of adopting a life cycle approach is to ensure that hazard management (as per Section 9) is an inherent part of each major stage of the pipeline system project (e.g., design, construction, operations etc.,). 9 Ronald D. Moen, R. & Norman, C., Circling Back Clearing up myths about the Deming cycle and seeing how it keeps evolving, Quality Progress, Published by American Society for Quality, Nov Accessed Dec CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 14 of 57

15 Plan Design Material Purchase Construct Operate Operational / Asset Changes Deactivate / Reactivate Decommission / Abandon Optimize life cycle cost New technology Integration of new facilities into existing pipeline systems Expected damage and deterioration mechanisms Expected inspection techniques Material specification(s) Optimize life cycle cost Manufacturing imperfections (manufacturing inspections) Material test reports Safe handling/shipping procedures Receipt inspections Storage methods Construction / installation defects (construction inspection) Commissioning Turn-over Expected damage and deterioration mechanisms Damage incidents Failure incidents Condition monitoring Maintenance, repair and replacement Change operating conditions Change of service fluid Addition of new facilities/facility types Deterioration mechanisms Condition Monitoring In-situ abandonment Removal / reclamation Figure 4: Scope of Processes and Mechanisms for Consideration in FIMP CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 15 of 57

16 3.3. Prioritization of Equipment Types and Processes While attempting to formulate the initial version of a FIMP, the Operating Company may need to prioritize certain equipment types and processes. This initial prioritization Table 2, can be based on a number of approaches (or combination thereof) based on what is most relevant for the Operating Company. Table 3 provides a suggested approach. Table 2: Potential Basis for Initial Prioritization of FIMP Scope Description Industry Incidents and Failures Company Incidents and Failures Corporate Policies and Objectives Approach Industry experience with similar facilities specifically damage incidents, failures and associated consequences. Corporate experience with similar facilities specifically damage incidents, failures and associated consequences. Could vary significantly but examples include: o Facilities critical to ensuring business continuity and o Equipment nearing end of design life (but perhaps no damage or failure incidents). Obviously, once the FIMP has been established, priorities will be established based upon the process itself (specifically, the identification of areas of significant risk as per Section 10.6). 4. Corporate Policies, Goals, Objectives and Organization 4.1. Policies, Goals and Objectives A FIMP is a key mechanism for translating corporate priorities into appropriate activities and tasks for execution as identified in Figure 5. CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 16 of 57

17 Corporate priorities Policies Values Objectives Integrity related policies Facilities Integrity Management Plan Integrity related goals Integrity related objectives Integrity related performance measures Figure 5: Translation of Corporate Priorities to Appropriate Integrity Activities A FIMP is a key mechanism for translating corporate priorities into appropriate activities and tasks for execution as identified in Figure 5. The FIMP document should contain, or appropriately reference documents describing relevant guiding corporate policies, values, objectives and performance measures. It would be expected that broadly these would commit to operating pipeline systems in a manner that protects the safety of the public, Operating Company employees and protection of the environment. Any specific facility integrity related goals and objectives would be described in detail in the FIMP and be aligned with the overarching corporate policies and objectives. Since goals and objectives are often defined in terms of potential outcomes, guidance should extend to the different types of consequences that are to be considered and the relative significance of those consequences (see Section 10.6). Potential consequences categories, aligned with CEPA s Integrity First Program, are provided in Figure 6. CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 17 of 57

18 Consequence Categories Safety Environment & Land Socio- Economic Business Public Safety Employee Safety Emergency Mgmt Land Air Water Flora & Fauna Noise Land Use Aboriginal Relations Workforce System Relaiability Financial Preparedness Ground Distrubance Total Emissions Watershed Disruption Habitat & Migration Disruption Impact of Operations Landowner Relations Land Use Agreements Safety Culture Service Disruption Revenue Response Ground Contaminatio n Ambient Air Quality Water Crossings Impact to Species Heritage Sites Customer Service Operating Budgets Repair & Reclamation Water Quality Capital Expenditure Figure 6: Consequence Categories for Consideration Adapted from CEPA Integrity First (Accessed December 2012) CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 18 of 57

19 4.2. Organization A critical element of successfully implementing the processes and activities associated with a FIMP will be a clear articulation of roles and responsibilities of Operating Company personnel for each aspect of the program. While organizational structures will vary across Operating Companies, the following functions typically associated with a management systems approach should be identified and assigned to appropriate individuals, groups or departments. Table 3: Key FIMP Roles and Responsibilities for Consideration Category FIMP Accountability Program Development and Improvement Records Management Program Planning, implementation and Reporting Program Audits, Reviews and Evaluations Communications Description The accountable individual(s), to whom the Operating Company delegates authority, should be clearly identified: o These functions are responsible for ensuring that appropriate human and financial resources are assigned to establishing, implementing, and maintaining the facility integrity management program. These functions are responsible for the development of the FIMP, identification of hazards and associated risk assessments and identification of hazard control activities as well as oversight of the FIMP processes. A critical element is the identification of key roles, outside of traditional integrity groups, that support FIMP. Specifically Sections: 3 to 5, 7 to 11 and These functions are responsible for ensuring that adequate records are maintained in support of FIMP development, implementation and associated activities. Due to the potentially large breadth and depth of these activities, this function may be dispersed across a number of departments and groups within the Operating Company. Specifically Section 6. These functions are responsible for planning and executing integrity related work along with documentation and analysis of results. Specifically Sections 12 through to 13. These functions work closely with the Program Development and Improvement functions to review, audit and assess the effectiveness of the FIMP and supporting activities. Specifically Section 14. Communications are critical through all stages of FIMP development, execution and management of change. As such, responsibilities for communicating, and nature of such communications, shall be established and documented for each stage of the FIMP process Performance Indicators and Targets As identified in Figure 5, a key element of successfully translating relevant corporate direction to a FIMP is to establish performance indicators (and associated targets). Further, the definition and monitoring of performance indicators provides a mechanism to monitor whether the FIMP is functioning effectively Performance Indicators In general, effective performance indicators should be reliable, repeatable, consistent, comparable, and appropriate to the intended need. CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 19 of 57

20 There are two main types of performance indicators: Leading and Lagging. These are described in further detail in Table 4 with examples provided in Appendix A2. In general, a well-structured approach would be comprised of both indicator types. Table 4: Two Types of Performance Indicators Category Leading Indicators Lagging Indicators Description Leading indicators measure the performance of a management system element or process, operating or maintenance procedure, control, mitigation, or evaluation in preventing incidents or loss of integrity events. These indicators look forward and are focused on prevention. Lagging indicators look at performance that can be measured in relation to the past. They evaluate events that have already occurred, such as leaks, ruptures, fires, and injuries, and the data collected as a result of these events can be utilized to prevent recurrence of similar events in the future. Lagging indicators are typically within an operators control to collect, are relatively easy to measure, and are typically comparable to industry data Performance Targets Targets for performance must be established against which the chosen performance indicators can be measured. From the comparison of results against targets, trends can be identified that can be used to modify or enhance FIMP activities (as warranted). In establishing realistic performance targets, a number of factors need to be considered. These are described in further detail in Table 5. CEPA Facilities Integrity Management Program Recommended Practice, 1st Edition, May 2013 Page 20 of 57

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