GPTC Distribution Integrity Management Guidance

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GPTC Distribution Integrity Management Guidance

• Lee Reynolds
• Leader Gas Standards
• NiSource Distribution Operations
• OGA Technical Seminar
• March 28, 2008

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Presentation Overview

• DIMP Background
• DIMP Elements
• Who is GPTC?
• GPTC DIMP Guidance
• Timelines

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DIMP BackgroundRelevant Reports

• American Gas Foundation Safety Performance and
  Integrity of the Natural Gas Distribution
  Infrastructure
• Sponsored by Industry with participation with
  Government
• Allegro Report - Safety Incidents on Natural Gas
  Distribution Systems Understanding the Hazards
• PHMSA Sponsored Report

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DIMP BackgroundPHMSA Public Meeting

• Public Meeting - December 16, 2004
• DOT Inspector General recommended Distribution
  Integrity should include the following operator
  requirements
• Understand the Infrastructure
• Identify and Characterize the Threats
• Determine How Best to Manage the Known Risks
  (Prevention, Detection, and Mitigation)

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Transmission
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Distribution
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DIMP BackgroundDistribution Vs Transmission

• There are significant differences in the design
  of gas distribution pipeline systems compared to
  the pipelines subject to current integrity
  management regulations (i.e., liquids and gas
  transmission). These include
• pipe size,
• operating pressure,
• materials, and
• the large number of branches and connections in
  distribution systems.
• These design differences significantly limit the
  applicability of the inspection techniques
  currently in use for transmission pipelines to
  distribution pipeline systems.

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DIMP Background
Report of Phase 1 Investigations
Published December 2005
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DIMP Background Report of Phase 1 Investigations
This effort concluded, as did the American Gas
Foundation Study before it, that distribution
pipelines are safe. Incidents continue to
occur, but their frequency has been reduced.
There is room for improvement. Implementing
integrity management, consistent with the
findings and conclusions of the work/study
groups, should help achieve additional
improvement.
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GPTC Discussion

• The following information developed by the GPTC
  DIMP Ad-Hoc Task Group.

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Who is the GPTC?

• Gas Piping Technology Committee
• Providing guidance for compliance with federal
  pipeline safety regulations since 1970
• Began as an ASME committee
• An ANSI Accredited Standards Committee - Z380 -
  since 1992
• Large, well balanced, consensus oriented committee

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Who is the GPTC?

• Unique Membership

• Regulators
• Federal
• State
• NTSB

• Gas Industry
• Distribution
• Manufacturing
• Transmission

• General Interest

Primary mission Write and publish guide material
(The GUIDE) for 49 CFR Parts 191 and 192
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What is The GUIDE?

• An ANSI standard Z380.1
• Provides how-to guidance for compliance
  activities
• Based on sound engineering and operating
  principles
• Advisory in nature does not restrict other
  methods of compliance

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What is in The GUIDE?

• Already covers most technical aspects of
  distribution system integrity
• Leak detection, grading and control
• Cast iron pipe maintenance
• Continuing surveillance
• Excess flow valves
• Recognizes distribution system and operator
  diversity

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Why DIMP Guidance?

• Needed for implementation of high level, flexible
  regulation
• Will help assure the flexibility needed for the
  wide variations of the gas distribution industry
• Assist operators in preparation of DIMP programs
• Aide in compliance with DIMP

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GPTC Appendix on DIMP (Draft)
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DIMP 7 Elements

• 1 Know the Distribution System How Its
  
  
  Operated Maintained
• 2 ID Threats (existing potential)
• 3 Evaluate and Rank groups based on risk
• 4 ID and Implement appropriate measures to
  manage risks
• 5 Measure performance and monitor results
• 6 Periodically evaluate improve program
• 7 Make periodic reports to government agencies

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1 - Know the Distribution System

• Location
• Material Composition
• Pipe Size
• Construction Methods
• Date of Installation
• Pressures
• Condition
• Pressures
• Other

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2 - Identify Threats (Existing Potential)

• The primary threats to a natural gas
  distribution system are as follows and are
  described under the instructions for the DOT
  Annual Report, PHMSA Form F7100-1.1.
• Corrosion
• Natural Forces
• Excavation
• Other Outside Forces
• Material or Welds
• Equipment
• Operations
• Other

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2 ID Threats (Continued)

• Determine if one or more threats causes a problem
• Answer appropriate questions to help determine
  whether the threat
• Exists throughout the system (General), or
• Is limited to a certain geographic region or
  material (Local).
• Alternatively, some risk models perform threat
  identification
• Some threats may be insignificant, non-existent,
  or not applicable (NA).

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2 ID Threats (Continued)

• The guidance provides sample questions (not
  all-inclusive)
• Sample Questions for the Corrosion Threat
• Sub-category External corrosion bare steel
  pipe
• Does bare steel exist in the system?
• Is the pipe cathodically protected?
• Have corrosion leaks occurred?
• Do exposed pipe inspections indicate external
  corrosion?

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2 ID Threats (Continued)

• Information evaluation may be done by any means
  suitable to the operator. Methods may include
• Simple stand-alone approach
• One or more subject matter experts review
  available data
• Periodic inter-departmental meetings
• Periodic meetings with subject matter experts
• More sophisticated approach
• Electronic database or work management system
• Risk evaluation software that compiles relevant
  information

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3 - Evaluate Rank Groups Based on Risk

• Implementing this element should result in a
  relative risk ranking of facilities or groups of
  facilities based on comparison to other
  facilities or groups of facilities.
• Risk Evaluation Methods
• Subject Matter Experts (SMEs)
• Determine where problems have occurred and if
  problems will likely occur in the future.
• Assign relative risk ranking to each group or
  groups of facilities experiencing problems
• Use of mathematical methods
• Software that performs risk evaluation

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3 - Evaluate Rank Groups Based on RiskEvaluate
Risks and Rank Facilities

• Risk Likelihood x Consequences
• Facilities not experiencing problems may be
  removed from the risk evaluation and no further
  action taken (except excavation threats).
• Stable or improving problem trends may require no
  further action.
• Frequency may be an indicator of Likelihood

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3 - Evaluate Rank Groups Based on RiskSample
Frequency Factors for Excavation Damage

• Low Few problems, excavators generally
  responsive, good map and locating records.
• Medium Moderate number of problems, excavators
  not very responsive, moderate map and locating
  records.
• High High number of problems, excavators
  non-responsive, poor or no map and locating
  records.

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3 - Evaluate Rank Groups Based on RiskSample
Consequence Factors for Excavation Damage

• Low Rural location, small diameter pipe, low
  operating pressure.
• Medium Residential location, medium diameter
  pipe, medium operating pressure.
• High Predominantly multi story buildings, large
  diameter pipe, high operating pressure.

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• 3 - Evaluate Rank Groups Based on Risk
• Sample Relative Risk Calculation

Determined by Operator
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3 - Evaluate Rank Groups Based on Risk Relative
Risk Calculations

• A high score is not an absolute measure of risk.
• Scores can help determine a relative risk between
  several groups for prioritizing.
• Can enhance the matrix by adding more detail
• Example A small diameter pipeline, operating at
  medium pressure and located in an urban area.
• Small diameter Low risk 1
• Medium pressure Med risk 2
• Urban area High risk 3
• Total consequence factor 6

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3 - Evaluate Rank Groups Based on
RiskValidation

• Validate the risk ranking
• Do the results and OM records focus on the same
  facilities or groups of facilities?
• Do the results agree with the SME experiences?
• If either answer is no, the differences need to
  be understood. Consider
• Review / revise evaluation process
• Gather more data
• Reevaluate the SME perspective

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3 - Evaluate Rank Groups Based on RiskRisk
Management

• Risk can be managed
• By eliminating or reducing the likelihood of a
  problem occurring
• By lessening the consequences of a potential
  problem.
• DIMP expects you to be pro-active in one or both

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4 - ID and Implement Appropriate Measures to
Manage Risks

• Accelerated actions/techniques operators may
  perform over and above the requirements of
  existing pipeline safety regulations to manage
  risks
• Operator may implement one or more accelerated
  actions when addressing one or more of the risks

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4 - ID and Implement Appropriate Measures to
Manage Risks Additional or Accelerated Actions
(A/A)

• The guidance gives examples of activities that
  are performed in addition to the requirements of
  the Code to manage risk.
• Determine which risk management techniques and
  practices are most appropriate.
• May implement one or more A/A, or other action
  determined by the operator, when addressing one
  or more of the risks.

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4 - ID and Implement Appropriate Measures to
Manage Risks Additional or Accelerated Actions
(A/A)
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4 - ID and Implement Appropriate Measures to
Manage Risks Additional or Accelerated Actions
(A/A)

• Leak management is an important risk management
  technique used by natural gas distribution
  operators to maintain the integrity of their
  distribution systems.
• Operators consider many factors specific to
  their geographical location and their specific
  distribution system to evaluate the severity of
  the leaks and determine the appropriate actions
  to mitigate the risk associated with the leaks.

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4 - ID and Implement Appropriate Measures to
Manage Risks Additional or Accelerated Actions
(A/A)

• An effective leak management program has the
  following basic elements.
• Locate the leaks in the distribution system
• Evaluate the actual or potential hazards
  associated with these leaks
• Act appropriately to mitigate these hazards
• Keep records and
• Self-assess to determine if additional actions
  are necessary to keep people and property safe.

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5 - Measure Performance Monitor Results

• Determine if a risk management technique or
  practice is effective
• Develop performance measures that match the risk
  management techniques or practice spelled out in
  your program
• Measures may be gathered and tracked for an
  entire system, specific geographic areas,
  material type, each facility or group of
  facilities or other reasonable category

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5 - Measure Performance Monitor
Results Performance Measures

• Address your specific risk management practices
• Should be something that can be counted, tracked,
  monitored and supported
• Select a critical few measurements
• Select performance measures that use data
  collected currently or in the past
• Where practical, use numeric performance
  measures, but
• Dont ignore non-numeric methods

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5 - Measure Performance Monitor Results Example
Performance Measures

• Corrosion
• Leaks due to external or internal corrosion
• Exposed pipe condition reports that found
  corrosion or coating damage
• Repairs required due to non-leaking pitting or
  coating damage (above/below ground)
• CP zones found with low protection levels

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5 - Measure Performance Monitor Results Example
Performance Measures

• Excavation
• Excavation caused damages (1st/2nd/3rd party)
• Damages per 1,000 tickets (normalized damages)
• Ratio of ticket no-show to total tickets received
• Failure by notification center to accurately
  transmit tickets to the operator
• Damages by cause, facility type (mains, services)
  and responsible party

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6 - Periodically Evaluate Improve Program

• Review content of written DIMP to ensure it is
  appropriate and accurate
• Analyze the effectiveness and success of risk
  management techniques, practices or accelerated
  actions adopted to respond to specific threats

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7 - Periodic Reporting

• Federal regulations, and in some cases state
  regulations, require periodic reports of
  information related to distribution integrity
  management programs.
• The operator should ensure that the information
  needed to complete those reports is being
  collected and is available when needed.
• Waiting on Rulemaking to determine specific
  reporting requirements.

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GPTC Guidance Availability

• GPTC will verify guidance is consistent with the
  NPRM after it is issued
• Anticipate only editorial changes since PHMSA has
  monitored the development process
• If no substantive changes, guidance will be
  available to the public
• Within weeks of the NPRM
• Through ANSI public review procedures
• Concurrently, it will be letter balloted for
  approval by the GPTC main body

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GPTC Guidance Summary

• DI guidance provides examples of
• How to identify threats
• A simple risk assessment method
• Risk management actions
• Performance measures
• Guidance will be available to the public
• Through ANSI public review procedures
• Within weeks of the NPRM if no substantive
  changes
• by end of July if revisions are needed

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Small OperatorsSimple, Handy Risk-based
Integrity Management Plan (SHRIMP)

• Being developed by the American Public Gas
  Association (APGA).
• SHRIMP is to be a decision management software
  system designed to assist the operators of
  natural gas utility systems to develop plans to
  manage the integrity of their distribution
  piping.
• This program is meant to assist utilities to
  comply with new Federal pipeline safety
  regulations requiring utilities to develop and
  implement integrity management plans.
• The basic purpose of the software is to generate
  a written integrity management plan that is
  appropriate for the unique circumstances of each
  utility.
• It is geared toward the needs of small utilities
  that lack in-house engineering and/or risk
  management expertise.

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Timelines

• Based on Latest Information
• Notice of Proposed Rulemaking (NPRM) June 2008
• 90 day comment period follows
• Final Rule
• December 2008
• Operator Plan Development
• 10/2009

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Questions??
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GPTC Distribution Integrity Management Guidance

• Lee Reynolds
• Leader Gas Standards
• NiSource Distribution Operations
• lreynolds_at_nisource.com
• 614-460-2261

OGA Technical Seminar March 28, 2008