Can operators include potential business consequences (e.g., curtailments, plant shutdown) in their risk determinations?
The focus of the integrity management rule is reducing the risk of pipeline failures to high consequence areas. The integrity management programs developed to comply with rule requirements must include the use of risk analysis to support operator integrity decisions. Operator risk analysis processes require the evaluation and measurement of both the probability and consequences of pipeline failures. The appropriate consequences to be included in these risk analyses depend on the decisions that are being supported by the risk analysis results. In the context of fulfilling requirements of the integrity management rule, operators should maintain a focus on the risk of failures to high consequence areas. If consequences considered in the risk analysis are expanded to include consequences related to operator business performance, then the operator must provide assurance that this approach does not skew decisions away from protection of HCAs. For example, consideration of operator business p
