DISTRIBUTION INTEGRITY

MANAGEMENT PLAN

IDENTIFY AND IMPLEMENT

MEASURES TO ADDRESS RISK

AND EVALUATING

PERFORMANCE 1

§192.1007(d)

§192.1007(d)- Identify and implement

measures to address risks

Determine and implement measures designed

to reduce the risks from failure of its gas

distribution pipeline. These measures must

include an effective leak management program

(unless all leaks are repaired when found).

§192.1007(e)– Measure Performance

Development and monitoring of performance to

evaluate the effectiveness of IM programs

§192.1007(f)– Periodic Evaluation

Revaluate threats and risks

Conduct complete program evaluations at

appropriate periods , but at least every 5 years

Must consider the results of performance

evaluations

§192.1007(E) &(F)

§192.1007(G)

§192.1007(g)– Report Results

Report, on an annual basis, the four measures

listed in paragraphs (e)(1)(i) through (e)(1)(iv) of

this section, as part of the annual report required

by § 191.11.

PURPOSE

Risk = Likelihood X Consequence

Target measures to reduce the likelihood

and/or the consequences of an occurrence

Preventative & mitigative (P&M) measures

Preventative – reduce likelihood

Mitigative – reduce consequences

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PURPOSE

Implement appropriate techniques to

manage and reduce risk based on the results

of the relative risk ranking.

Address facilities with high relative risk.

(Criteria?)

More than just pipe replacement.

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PURPOSE

Measures are dependent on:

The asset or facility group being addressed

The associated threat(s)

Whether the threat is current or potential

The viability of the action in managing the

relevant risk factors

Short term, long term, or condition specific

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EXAMPLES

Accelerate replacement of unsatisfactory pipe or facilities

Perform better leak surveys

Modify locating, maintenance, patrolling, monitoring, construction, and records procedures

Condition specific measures

Weather related leak surveys or patrols

EXAMPLES

Implement results of ongoing R&D

Plans to shut in systems during hurricanes

or flooding events

Monthly rectifier readings

Riser replacement programs

Cast iron surveys after earthquakes

REFERENCE MATERIAL

• GPTC Appendix G-192-8 section 6.3.

• APGA SHRIMP application provides a

pick list of possible

Additional/Accelerated Actions (“A/A

Actions”). Handout contains the list of

these actions.

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11/14/2010

CASE STUDY

Inspector watching a saddle fusion in the

field

Identified that joiner was not following

company procedures

Inspector asked to

cut out and test fusion

BACKGROUND

Joint passed visual examination

BACKGROUND

Joint after testing

BACKGROUND

Joiner worked for 5 years

At least 135 installations in past 2

years – known locations

No location or number history for other

3 years

IMPACT ON IM

Change in threats Incorrect operations Construction/joining Once all bad joints removed does the

threat decrease?

Change in risk Risk increases for system because of

unknown number and locations

IMPACT ON IM

P&M measures

Remove all known fusions by joiner

Determine other potential locations

Monitor other installations

Performance measures

Number of fusions removed

“EFFECTIVE” LEAK MANAGEMENT

An Effective Leak Management Program includes:

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

Self-assess to determine if leak

management program is effective.

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GPTC SECTION 6.3 SELF AUDITS

Perform self-audits, define metrics, and

monitor trends such as:

(a) Schedule of leak survey - meet timeframes?

(b) Survey effectiveness - consistent evaluation?

(c) Repair scheduling - made within specified time?

(d) Repair effectiveness – recheck for leaks?

(e) Leak records – maintained as required?

11/14/2010

18

PERFORMANCE MEASURES - ANNUAL REPORT FORM

19

Reported Performance Measures

1. Number of Hazardous Leaks

Eliminated or Repaired by

cause

2. Number of Excavation

Damages

3. Number of Excavation Tickets

4. Total number of leaks

eliminated or repaired by cause

Must also report EFV metrics.

PERFORMANCE MEASURES

Two additional required performance measures

operators must develop and monitor but not

report are:

Number of hazardous leaks either eliminated

or repaired categorized by material

Any additional measures the operator

determines are needed to evaluate the

effectiveness of the operator’s IM program in

controlling each identified threat.

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MECHANICAL FITTING FAILURE REPORT

21

FAQs about

Mechanical

Fittings:

C.5.3

C.5.4

C.5.5

C.5.6

ADB 2012-07

ADB – 2014-05

Guidance for Strengthening Pipeline

Safety Through Rigorous Program

Evaluation and Meaningful Metrics

Issued October 15, 2014

ADB – 2014-05

Describes process for any program

evaluation for continuous improvement

Written for integrity management evaluation,

but processes useful for other program

evaluations

PROGRAM EVALUATION

Ongoing process to measure, assess and

evaluate program performance using leading

and lagging metrics

Leading indicators measure the accomplishment

and effectives of programs and associated

activities

Lagging indicators measure outcomes of the

programs and activities, provide documented

success or failure of activities.

PROGRAM EVALUATION

Leading indicators

How well program is being implemented

Are we doing what we said we would do?

Examples include:

Use of P&M or accelerated action activities

Collection of missing or unknown data

Pipe replacement programs

PROGRAM EVALUATION

Lagging indicators

May be considered results

How well did we do it

Examples include:

Leaks by cause

Third party damage

Repaired leaks, defects or pipe replacements

PERFORMANCE MEASURES

Develop a performance measure for each measure

or groups of measures to reduce risk (FAQ C.4.e.2)

May use existing data to develop baselines from

which to track trends of performance measures.

Use numeric data (counted, tracked, monitored,

supported, reproducible).

Performance measures are used to determine if

risk management techniques or practices are

effective.

3/30/11 - 27 -

PROGRAM EVALUATION

Formal controlled process for continual

improvement of programs

Series of systematic steps for learning,

analysis and knowledge of process

Integral part of the quality control/quality

assurance process

PROGRAM EVALUATION

Written detailed procedures describing

process

Should include sufficient detail about

processes/procedures for an outside

observer, or a new employee becoming

involved to understand how an activity is

performed and provide consistent,

reproducible results.

PROGRAM EVALUATION

Program evaluation

Following processes and regulatory

requirements

Program effectiveness

Increasing integrity of facilities and improving

safety

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30

PROGRAM EVALUATION

PDCA (Plan-do-check-act)

PDSA (plan-do-study-act)

Deming cycle

PROGRAM EVALUATION - PLAN

Establish processes, objectives and goals

Select metrics

What will be measured

How it is measured

Who will provide data

When will data be collected

Why the metric was chosen

Implementation metrics – planned activities such as pipeline replacement, or accelerated actions

PERFORMANCE MEASURES

Examples of performance measures can be found in:

GPTC Appendix G-192-8 Section 7.2 Examples of performance measures

APGA SHRIMP (spreadsheet handout)

Section 9 of ASME B31.8S-2004, “Managing System Integrity of Gas Pipelines” can also be used for the selection of performance measures that can be applied to gas distribution systems

3/30/11 33

PROGRAM EVALUATION - PLAN

Goals or metrics periodically reaffirmed

Can change over time

5 year pipe replacement program – goes away after completed

Can be normalized over time, mileage, pipe material or throughput to reduce data spikes

5 year rolling average

Per 100, or 1000 miles

Goals or metrics shared

PROGRAM EVALUATION - METRICS

Characteristics of effective metrics

Reliable – unbiased, specific and discrete

Repeatable – similar data and results

Relevant – meaningful to system

Meaningful – sufficient data to measure +/-

change

Zero year after year not a useful metric

Easy to use and compare – across industry or

company

PERFORMANCE MEASURES

Short term goals such as effect of vintage pipe replacement programs

Long term goals – monitored every year

Shared goals such as monitoring third party damage as part of both damage prevention and IM

Specific goals for geographic regions or parts of system

3/30/11 36

PROGRAM EVALUATION - DO

Implement and execute the processes

P&M measures or additional actions

Perform required elements

Assessments for IM

Stakeholder communication

Regulatory required tests and inspections

Collect data or information

How often is data collected

PROGRAM EVALUATION - CHECK

Outcomes monitored to test validity for

success, problems or improvement

Analyze the data against requirements and

expectations

May not know at beginning what data will show

Reach expected goals or performance levels

Perform all the implementation activities

Number of additional actions or activities

PROGRAM EVALUATION - CHECK

Report results to determine if objectives and

results being achieved

Look for trends and deviations

Analyze differences to determine causes and

corrective actions

Determine if using proper metrics

Zero year after year valid?

PROGRAM EVALUATION – ACT

Integrate the learning generated by the process

Identify corrective actions where actual results differ significantly from expected results

Accuracy of data or identified metric

Procedures inadequate or inaccurate

Changes to metrics - adding new or deleting old out of date

PROGRAM EVALUATION – ACT

Implement the necessary changes

Changes identified, but never implemented

Person responsible for implementation

Documentation of implementation

Management of change process

Only required for IM, but good practice

PROGRAM REVIEW FREQUENCY

Determine Interval for Program Review

and Evaluation

At least every 5 years

Plan evaluation frequency

Long enough for meaningful

changes

Short enough to recognize trends

Additional evaluations as needed

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3/30/11

PROGRAM REVIEW FREQUENCY

Based on complexity of system and changes

in risk factors

Could be similar frequency as review of

operational plans and procedures.

Could be after a plan milestone such as a

major pipe replacement program.

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3/30/11

PROGRAM REVIEW FREQUENCY

Determine Interval for Program Review and

Evaluation cont…

Triggered by needed change to performance

measure or measure to reduce risk.

Dependant on time frame when the operator

anticipates that the measure to reduce risk

will produce meaningful results

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3/30/11

PROGRAM EVALUATION

Periodic self assessments

Internal/external

Management review

Other evaluations (including regulatory)

Reviews validate conclusions

Reviews provide performance feedback and

improvements to process

WRITTEN PROCEDURES

What is the evaluation process?

Scope, objectives and frequency of review

Steps and documentation

Data collection

Performance goals

Who is responsible or participates in review

How deviations are addressed

PROGRAM EVALUATION PROCEDURE

Procedure must describe the program

evaluation actions and include:

Frequency of review

Incorporate new system information

Re-evaluation of threats and risk

Frequency of measures to reduce risk

Effectiveness of measures to reduce risk

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3/30/11

PROGRAM EVALUATION PROCEDURE

Procedure must describe the program

evaluation actions and include

(cont..):

Modify the measures to reduce risk and

refine/improve as needed

Performance measures, their

effectiveness, and if they are not still

appropriate, refine/improve

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3/30/11

WRITTEN PROCEDURES

What is the evaluation process?

Corrective actions or changes

Responsibility for implementation of changes

Documentation requirements

Define significant changes

Example – OQ, O&M Manual

Communication of changes

Record keeping requirements

EFFECTIVENESS EVALUATIONS

Is the program doing what is desired and

expected

Deviations from expectations

Right metrics

Documentation of deviations

Having data is not an evaluation

Need to understand what information and

data means

CASE STUDY

Gas distribution system on New

Jersey shore

Both barrier islands and mainland

Superstorm Sandy Landfall on 10/29/2012

Storm surge ≥13.3 feet

System pressurized

during storm

CASE STUDY - CHANGING

THREATS

After storm hit

• Curtailed service to 31,000 customers

• Repressurized or replaced 270 miles of main in less that 6 weeks

• Installed one mile of new 12” steel main in 3 weeks

12” 60lb main

CHANGING THREATS

Roads and bridges washed away Sand drifts 7 feet tall Debris and flooding Leaks Valves and other equipment buried

CHANGING THREATS

Threats have changed

Corrosion threats

External

Internal

CHANGING THREATS

Threats have changed

Outside force damage

Third party damage

Materials and construction

PLAN EVALUATION

Identified threats and therefore

risk rankings should change

Should this event trigger an

integrity management evaluation?

QUESTIONS?

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