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the voice and choice of public gas Integrity Management and Other Issues John Erickson American Public Gas Association What Is APGA? the voice and choice of public gas • 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 DIMP Implementation the voice and choice of public gas • 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 OPERATORS the voice and choice of public gas • 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 REGULATORS the voice and choice of public gas • 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 DIMP Inspection Form the voice and choice of public gas • 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 Item 4 the voice and choice of public gas • 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.)? Items 7-9 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.)? Items12-13 the voice and choice of public gas • 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? Items 23-25 the voice and choice of public gas • 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? Item 26 the voice and choice of public gas • 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 Item 35, 37, 39 the voice and choice of public gas • 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? Cross reference available the voice and choice of public gas Cross reference available the voice and choice of public gas the voice and choice of public gas Enhancements to SHRIMP the voice and choice of public gas • 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 Other Enhancements the voice and choice of public gas • 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) New Inspection Form the voice and choice of public gas • 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? Other Issues the voice and choice of public gas Alternative Enforcement the voice and choice of public gas • 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 Pipeline Safety User Fees the voice and choice of public gas • 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 Pipeline Safety Management the voice and choice of public gas 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 Pipeline Safety Management the voice and choice of public gas 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 Pipeline Safety Management the voice and choice of public gas 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 Drug and Alcohol Plan Tool the voice and choice of public gas • 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 O&M Plan Tool the voice and choice of public gas • 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 Leak City Conference the voice and choice of public gas • 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 the voice and choice of public gas Thank You!