Integrity Management and Other Issues

John EricksonAmerican Public Gas Association

the voice and choice of public gas

the voice and choice of public gasWhat Is APGA?• The National Trade Association for Publicly-Owned Gas Utilities

• Over 700 member utilities in 36 states• Created in 1961 • New mission in 2004• Moved to Washington, DC• Expanded to 10 staff

the voice and choice of public gasDIMP Implementation

• APGA believes the implementation of the rule is often contrary to the framework laid out in the Phase 1 report and the rule

• Only a few regulators and operators were involved throughout the DIMP development process

• As a result, not all operators and regulators understand the underlying principles of DIMP

the voice and choice of public gasOPERATORS

• Ideally, DIMP should elicit critical thinking about problem areas on the system and actions to address those problems

• Operators have used DIMP as an opportunity to step back and look at the big picture rather than just do what’s in the regulations

• Some operators have not given enough thought to DIMP plans and/or been too quick to accept the output of model plans

the voice and choice of public gasREGULATORS

• Auditing DIMP compliance requires a different approach than auditing rectifier inspections

• The DIMP Inspection Form focuses on minutia in the language of the rule rather than the big picture

• More questions deal with documenting processes than whether the operator has developed a plan appropriate for the unique circumstances of the system

the voice and choice of public gasDIMP Inspection Form

• 51 items• Focus on written procedures describing

how the plan was developed, rather that whether the plan is appropriate for the operator’s system

• Let’s look at some of the items

the voice and choice of public gasItem 4

• 4. .1007(a)(1) Do the written procedures identify or reference the appropriate sources used to determine the following characteristics necessary to assess the threats and risks to the integrity of the pipeline: – Design (e.g. type of construction, inserted pipe, rehabilitated

pipe method, materials, sizes, dates of installation, mains and services, etc.)?

– Operating Conditions (e.g. pressure, gas quality, etc.)?– Operating Environmental Factors (e.g. corrosive soil conditions,

frost heave, land subsidence, landslides, washouts, snow damage, external heat sources, business districts, wall-to-wall paving, population density, difficult to evacuate facilities, valve placement, etc.)?

the voice and choice of public gas

• 7. .1007(a)(3) Does the plan contain written procedures to identify additional information that is needed to fill gaps due to missing, inaccurate, or incomplete records? 1007(a)(3)

• 8. .1007(a)(3)Does the plan list the additional information needed to fill gaps due to missing, inaccurate, or incomplete records?

• 9. .1007(a)(3) Do the written procedures specify the means to collect the additional information needed to fill gaps due to missing, inaccurate, or incomplete records (e.g., O&M activities, field surveys, One-Call System, etc.)?

Items 7-9

the voice and choice of public gasItems12-13

• 12. .1007(a) Does the documentation provided by the operator demonstrate implementation of the element “Knowledge of the System”?

• 13. .1007(a) Has the operator demonstrated an understanding of its system?

the voice and choice of public gasItems 23-25

• 23. .1007 (c) Do the written procedures to evaluate and rank risk consider each applicable current and potential threat?

• 24. 1007 (c) Do the written procedures to evaluate and rank risk consider the likelihood of failure associated with each threat?

• 25. 1007 (c) Do the written procedures to evaluate and rank risk consider the potential consequence of such a failure?

the voice and choice of public gasItem 26

• 1007 (c) If subdivision of system occurs, does the plan subdivide the system into regions with similar characteristics and for which similar actions are likely to be effective in reducing risk? Briefly describe the approach

the voice and choice of public gasItem 35, 37, 39

• 35. Does the plan contain written procedures for how the operator established a baseline for each performance measure?

• 37. Does the operator have written procedures to collect the data for each performance measure?

• 39. .1007 (e) When measures are required to reduce risk, do the written procedures provide how their effectiveness will be measured?

the voice and choice of public gasCross reference available

the voice and choice of public gasCross reference available

the voice and choice of public gas

the voice and choice of public gasEnhancements to SHRIMP

• Over 1,300 SHRIMP users – Large and small

• Added a ton of written procedures• Improve the Risk Ranking model• Create means to track and analyze

performance measures within SHRIMP• Allow automatic submission of annual

reports from within SHRIMP• Continue feedback from users

the voice and choice of public gasOther Enhancements

• Fix the “Replaces Plan Dated” Field• Add additional detail about use of outside

data• Make the plan more readable• Include a summary that lists sections, AA’s

and PM’s together• Changes to the threat assessment

processes and risk model (some significant)

the voice and choice of public gasNew Inspection Form

• Initial DIMP audits focused on the written plan

• Follow-up audits will focus on:– Is the operator following the plan?– Are additional actions effective in reducing

risk?– Are performance measures being tracked?– If required by plan, are re-evaluations being

done?

the voice and choice of public gasOther Issues

the voice and choice of public gasAlternative Enforcement

• More fallout from San Bruno• Only 14 states issued civil penalties 2011• 17 states have not issued civil penalties in

the last 10 years• Perception: Lax state enforcement• Some states use alternatives to fines, such

as requiring spending on improvements• NAPSR and APGA are working together

the voice and choice of public gasPipeline Safety User Fees

• Since 1986, PHMSA budget paid via fees on transmission mileage and LNG

• $23.99 per mile in 1986• $231 per mile in 2012, a 500% real increase• Pipelines want fee on distribution mileage or

a FERC “tracker” that adjusts their rates• APGA opposes – increases should be

passed on to customers in pipeline rates• Pipelines are reluctant because rate case

would consider all costs, not just the fee

the voice and choice of public gasPipeline Safety Management

Systems• NTSB Recommendation to API• API committee has just 1 public gas rep• Committee is developing a standard

appropriate for a large, multistate pipeline• Major elements are OK, but• Standard is way too prescriptive for

distribution operators

the voice and choice of public gasPipeline Safety Management

Systems Elements• Management Leadership and Commitment • Risk Management• Operational Controls• Incident Investigation, Evaluation and Lessons

Learned• Safety Assurance or Continuous Improvement• Safety Management System Monitoring,

Measurement, Analysis and Improvement• Training, Qualification and Development• Emergency Preparedness and Response• Stakeholder Engagement

the voice and choice of public gasPipeline Safety Management

Systems• APGA will continue to participate and

object at every opportunity• Focus is now on preventing this from

ever being adopted as an ANSI standard and/or being incorporated in Part 192 regulations

the voice and choice of public gasDrug and Alcohol Plan Tool

• A “SHRIMP-like” Q&A process that creates a drug and alcohol plan

• Has been available for several years• We will keep it up to date with rule

changes for $495/year

the voice and choice of public gasO&M Plan Tool

• A “SHRIMP-like” Q&A process that creates an operations and maintenance plan

• If user is also a SHRIMP subscriber, the tool will merge DIMP inspection and maintenance requirements into the O&M

• Will also ensure that operator qualification evaluations match the task procedures

the voice and choice of public gasLeak City Conference

• Mark your calendars for September 9-12• The SIF will once again offer OQ

qualification testing in certain classes• The sun will shine• The humidity will be low• BBQ and fried chicken will be eaten

Thank You!

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