Transcript OPS Initiative on Public Education Programs

Distribution Integrity
Management
John Erickson, PE
American Public Gas Association
Distribution Integrity
Management Rule
History & Future
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2001 – Liquid Integrity Management Rule
2003 – Transmission IMP Rule
2004 – DOT Inspector General Testifies
2005 – PHMSA Issues Phase 1 Report
2006 – GPTC Prepares Guidance
2008 – Notice of Proposed Rule 6/25/08
2009 – Expect final Rule
18 months for implementation
Phase 1: DIMP Structure
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1. Development of an integrity management plan
2. Know your infrastructure
3. Identify threats (existing and potential)
4. Assess and prioritize risk
5. Identify and implement measures to mitigate
risks
• 6. Measure and monitor performance and results
• 7. Report results
Know Your Infrastructure
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Material(s) of construction
Leak history
Repair history
Inspection records:
– Cathodic protection
– Leakage surveys
– Exposed pipe inspections
Identify Threats
• A “threat” is something that can lead to an
unplanned release of gas
• Phase 1 identified 8 threats:
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Corrosion
Material or Welds
Natural Forces
Equipment
Excavation
Operations
Other Outside Force Damage
Other
Assess and Prioritize Risk
• Two general approaches:
– The Subject Matter Expert method.
• Review and ranking by the persons most
knowledgeable about the system
– Algorithm methods.
• Numerical scores based on scores assigned to
various attributes of the system
• Final determination by SME’s
Implement Actions to
Reduce Risks
• DIMP does not presume that additional
actions will always be required.*
• GPTC offers suggestions for each threat
• Operators may elect to continue existing
inspection/repair/replacement programs,
choose actions from the GPTC list or
develop their own actions to address threats
* See next slide for the exception
*Except For Inappropriate
Operation
• Each plan must have a section titled
“Assuring Individual Performance”
• List risk management measures to evaluate
and manage the contribution of human error
and intervention to risk (e.g., changes to the
role or expertise of people), and implement
measures appropriate to address the risk.
Continued
• Also list existing programs the operator has
implemented to comply with
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Sec. 192.614 (damage prevention programs);
Sec. 192.616 (public awareness);
Subpart N (qualification of pipeline personnel),
49 CFR Part 199 (drug and alcohol testing).
More Specific Requirements
• Excess Flow Valves on new and replaced single
residential services > 10 psig
• Leak classification system
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Locate the leak
Evaluate its severity
Act appropriately to mitigate the leak
Keep records
Self assess
GPTC Leak Grading
• Grade 1 – Immediately hazardous to the
public or property – Fix immediately
• Grade 2 – Not immediately hazardous –
may be repaired or monitored for limited
time
• Grade 3 – Not immediately hazardous and
may be monitored indefinitely
Fix All Leaks
• Will the rule require grading even if all
leaks are immediately repaired?
• APGA will urge PHMSA to accept find and
fix as an acceptable alternative
• Operators would still have to track
immediately hazardous leaks for
performance measurement
EFV Requirements
• Congress instructed DOT to include a June
1, 2008 deadline in DIMP rule
• PHMSA has written to states urging them to
encourage operators to install EFVs June 1
• PHMSA has issued a Advisory Bulletin
• Not a legal requirement, but APGA urges
operators to meet the June 1 deadline
EFV Installation
Requirements
• New and replaced only (no retrofit)
• Services to single residences (not branched
services, not multi-family, not commercial
or industrial)
• Continuously operating <= 10 psig
• Would not interfere with clearing liquids
from the service and no history of plugging
due to debris in the gas
EFV Considerations
• Recommend closure flow 50% greater than
connected load on service
• New utilization equipment affects service
line design
– Tank-less water heaters draw as much as 5
times more gas than conventional water heaters
– Home electric generators
• Consider ¾” or 1” PE and 800 cfh EFV
rather than ½” and 300/400 EFV
Measure and Monitor
Results
• How will you measure whether your
program is successful at reducing risks?
• Internal and external performance measures
– Internal – Used by the utility
– External – Submitted to the State/Federal
regulators
External Measures –
Reported to State & PHMSA
• Number of hazardous leaks eliminated by
cause;
• Number of excavation damages;
• Number of excavation tickets;
• Number of EFVs installed;
Internal Measures
• Total number of leaks eliminated by cause;
• Number of hazardous leaks eliminated by
material; and
• Any additional measures to evaluate the
effectiveness of the operator's program in
controlling each identified threat.
Plastic Pipe Failure
Reporting
• Report detailed analysis of all failures on
plastic pipe and components within 90 days
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location of the failure in the system,
nominal pipe size,
material type,
nature of failure,
pipe manufacturer, lot number and date of
manufacture, and other information that can be
found in markings on the failed pipe
Why?
• Operators with > 70% of installed plastic
pipe participate in the existing voluntary
reporting program
• A team of government and industry experts
reviews data every 6 months
• PHMSA has issued advisory bulletins based
on the voluntary program
Why?
• According to PHMSA, small utilities need
the raw data so they can do their own
analyses
• Real reason: Some state and federal
regulators want access to the raw data
• APGA opposes mandatory submission –
poses a burden on small systems with no
benefit (getting 100% will not provide
better statistical certainty of results)
Recordkeeping
• 10 years for performance measures
• For the life of the system for:
– Rationale for all changes to the written IM plan
– All documents used in developing threat
assessments
– A written procedure for ranking the threats
Continuing Improvement
• Operators must perform a complete
program evaluation at least every 5 years
• If performance measures show
improvement, no further action required,
however,
• If performance measures show no progress
or declines, operators must modify DIM
Plans
Master Meter & LP Piping
Operators
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Infrastructure knowledge
Identify threats
Implement measures to mitigate risks
Measure performance, monitor results, and
evaluate effectiveness. # of leaks repaired
by cause
• Periodic evaluation and improvement
MM & LP Records
• The operator must maintain, for the useful
life of the pipeline, the following records:
– A written IM program;
– Documents supporting threat identification;
– Documents showing the location and material
of all piping and appurtenances (for preexisting pipelines, as much as is known)
GPTC Guidance
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Geared toward larger operators
Guidance only, not mandatory
Lists of infrastructure knowledge elements
Lists of questions for threat assessment
Lists of possible additional measures
Lists of possible performance measures
Published along with final rule
Introducing SHRIMP!
• Simple, Handy, Risk-based Integrity
Management Plan
SHRIMP
• Envision a software product similar to tax
preparation software (TurboTax)
• SHRIMP will ask the user a series of
questions about the system and its
inspection and maintenance history
• Questions will change based on answers
• Output will be a nearly complete DIM Plan
SHRIMP Timing
• Due 6 months after final rule
• GOAL: Have SHRIMP trial version
available when final rule is issued.
• That way utilities can decide whether to use
SHRIMP or other means to develop DIMP
SHRIMP Development
• Advisory Group made up of state
regulators, federal regulators and industry
• Technical Toolboxes is software developer
• Heath and Associates, Technical Consultant
• Viadata, Technical Consultant
Questions?
• [email protected]
• 202-464-0834
• www.apga.org