APGA Security and Integrity Foundation the voice and choice of public gas SIF Update Gerry Lee, P.E. APGA Security and Integrity Foundation

Security & Integrity Foundation (SIF) Independent of APGA Assist small operators to operate safe gas distribution systems “Small operators” include — Natural gas utilities Master meter, and Propane piping systems For 10 years funded through a cooperative agreement with PHMSA Is now self-sufficient

SIF Programs Operator Qualification Evaluations Operation and Maintenance Procedures SHRIMP Operator Qualification Training O&M Manual Creation Tool OQ Plan Creation Tool Public Awareness Plan Creation Tool

SHRIMP

SHRIMP Development Funded through a cooperative agreement with PHMSA Advisory Group made up of state regulators, federal regulators and industry Technical Toolboxes, Software developer Heath and Associates, Technical Consultant Viadata, Technical Consultant

Simple, Handy, Risk-Based, Integrity Management Program Compliant with Federal Distribution Integrity Management Program regulation Used by systems of all types and sizes (master meter, municipal, natural gas, propane, investor owned) Pre-audited and updated based on results More than1,192 users representing over 6,600,000 meters nationally

SHRIMP On-line software product similar to tax preparation software (TurboTax) SHRIMP asks the user a series of questions about the system and its inspection and maintenance history Questions change based on answers Output is a customized DIMP Plan addressing all the elements and any other provisions in the rule

Accurate Records Your DIMP plan is no better than the accuracy of your records allows!

Changes To SHRIMP We continually modify SHRIMP based on feedback from regulators and users There have been 47 updates Current SHRIMP version is 2.1.16 A DIMP plan will only include updates if it has been re-generated with the latest version Changes are described in Announcements displayed when you next log in to SHRIMP Emails notices are sent for major revisions

Cross Reference to Inspection Form PHMSA Forms 22 and 23 are for inspecting written DIMP plans Form 22 is for utilities and large LP systems Form 23 is for master meter and small LP pipeline operators The forms and a cross reference document are available under the Resources tab in SHRIMP Lists each Form 22 item and where in a SHRIMP written plan it is addressed Form 24 for auditing plan implementation

Program Re-evaluation Required at least once every 5 years August 2, 2011 was the effective date of the rule August 2, 2016 was 5 years SHRIMP includes a process to perform and track program re-evaluation Rule requires that program re-evaluation include reviewing performance measures

Performance Measures New Written Plan Section 11: "ANALYSIS OF RISK BASED PERFORMANCE MEASURES" It is now possible to track some performance measures in SHRIMP and use SHRIMP’s statistical analysis capabilities Currently only performance measures that coincide with threat assessment data are trackable Will be adding additional capabilities

BASELINE Performance Measures

Performance Measures

Benchmarking Allows users to compare with other SHRIMP users Only aggregated data – cannot view other user’s data Can select filters to compare with peer group

Benchmarking

Benchmarking

Benchmarking

Benchmarking Cannot create a peer group that is just one system Peer group must be at least 3 other SHRIMP users or will not be displayed We welcome suggestions for other benchmarks we could calculate with SHRIMP data

Coming Enhancements Major revisions to threat assessment and risk ranking sections All system segments for all threats will now appear in the risk ranking section, regardless of relative risk score Consequence questions will be asked of all system segments Users will be able to re-rank relative risk and assign AAs and PMs to any threat-segment

All Threat Assessments All threat assessments that collect leak repair, damage, failure, locate ticket, etc. data will now include probability score weighting based on: MK trend analysis (this is done now) Comparison with average of all SHRIMP users, and Where users subsection by geography, comparison of the subsection average with the user’s average

Excavation Threat Assessment Major changes that will require re-entering data and answering questions Will include trending of excavation tickets and damages per 1000 tickets Will include comparison to SHRIMP users and system averages for damages/1000 tickets and excavation tickets All subsections will appear in risk ranking chapter

Natural Forces Threat Assessment Check all that occur in areas where you have pipelines: Subsidence, Frost heave, Earthquakes, Landslides/mudslide, Lightning, Flooding, Scouring/washouts due to flowing water Falling chunks of snow or ice High winds/hurricanes/tornados Other natural causes not listed above. (If they choose this, when going through the sectioning ask to describe the natural forces threat.)

Natural Forces Threat Assessment User can create as many sub-sections as necessary for each checked sub-threat For each subsection, user will be asked to: Assign a name Define the geographic area(s) where the sub-threat exists Enter the miles of main and # of services Answer probability assessment questions Answer consequence assessment questions

Cross bore as a sub-threat under excavation. Possible questions: Under consideration Cross bore as a sub-threat under excavation. Possible questions: Have gas lines been installed by HDD? Could sewer lines in these areas be located and marked? In these areas, are sewer lines deep or shallow? Slabs or basements Were gas lines installed where sewer laterals might exist? Have cross bores been found? Have laterals been inspected for cross bores?

Existing and Potential Threats Rule requires that DIMP plans consider existing and potential threats SHRIMP interviews address both. For example, for corrosion threat: Corrosion leaks, metal loss = Existing threat Stray currents, low CP = Potential threat SHRIMP written plans will be modified to separately list existing and potential threats

Interacting Threats “Two or more threats acting on a pipe or pipe segment that increase the probability of failure to level significantly greater than the effects of the threats acting alone” Kiefner & Associates, Inc. Example: The presence of cast iron or brittle plastic pipe in an area prone to earth movement

Interacting Threats The rule does not mention interacting threats However, SHRIMP’s risk ranking model includes questions regarding interacting threats For example: Low CP levels and stray currents raise the probability of corrosion, but do not affect the pipeline segment’s risk of excavation damage

Interacting Threats Not all threats are interacting Interacting threats are uncommon on low stress distribution lines

Form 24 Form 24 is for auditing whether the operator has followed through with all the actions required by its written DIMP plan SHRIMP includes an implementation plan that summarizes all these actions Some items in form 24 required changes to SHRIMP’s written DIMP plan template

Form 24 For example, item 29. Periodic Evaluation - If any established performance measures indicated an increase in risk beyond an acceptable level (as established in the DIMP plan), were new risk reduction measures implemented along with their associated performance measures? Chapter 8 of the SHRIMP Plan template is being revised to define unacceptable increase in risk

Top Ten SHRIMP Mistakes Didn’t read the Users’ Guide Didn’t complete all information (Implementation Plan, most often) Didn’t download and save the Plan Didn’t read the Plan Accepted without question all SHRIMP rankings

Top Ten SHRIMP Mistakes Didn’t consider whether to create subsections Didn’t enter all information in the Implementation Plan Didn’t complete the Data Source fields Didn’t download and read the inspection form prior to audit Didn’t identify potential threats

Other SIF Programs Operator qualification evaluations Evaluations measure knowledge, skills and abilities (KSA’s) and ability to recognize and react to abnormal operating conditions (AOC’s) KSA’s and AOC’s were identified for each task by subject matter experts Evaluations include both written tests and observation performing the task SIF carefully screens the qualifications of the evaluators

Other SIF Programs Operation and Maintenance Procedures Written procedure for each of ~ 100 covered tasks Each procedure includes: List of materials and equipment needed Discussion of any worker safety issues Step by step procedure, and How to recognize and react to AOC’s Download for free from www.apgasif.org

Other SIF Programs Also available: Under development: Drug and alcohol plan creation tool Under development: Operations and maintenance manual creation tool Public awareness plan creation tool Operator qualification plan creation tool

Questions?