SHRIMP Implementation Plan - Western Regional Gas Conference

SHRIMP
John Erickson, PE
APGA Security and Integrity Foundation (SIF)
August 22, 2012
What is the Security and Integrity Foundation?
• 501 c3 Non-profit foundation created by APGA in 2005
to assist small operators
• Receives funding from the Pipeline And Hazardous
Materials Safety Administration (PHMSA) thru
cooperative agreement
• Provides OQ evaluations, O&M procedures, D&A plans
and more, in addition to DIMP
• Creator of SHRIMP
What is SHRIMP?
• Simple, Handy Risk-based Integrity Management Plan
• 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 will be a nearly complete DIM Plan
• >1,600 users overall, including utilities, master meter
and LP-piping system operators and farm taps
Size Range of SHRIMP Users
400
359
350
310
300
250
200
127
150
82
100
54
50
23
0
10
100
1000
10000
100000
More
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
DIMP Compliance Audits
• Have been ongoing since August 2, 2011
• DIMP is new to state inspectors, too
• Audit for is available at PHMSA’s website and
www.apgasif.org
• Also available at www.apgasif.org is a document
showing how SHRIMP addresses each audit form item
• The SHRIMP Plan has been revised to address all items
• Major addition – Implementation Plan
SHRIMP Implementation Plan
• New Chapter 11.1 in SHRIMP written DIMP Plans
• SHRIMP automatically lists all action items from plan in 3
sections
• Section A describes how user will modify procedures,
policies and/or recordkeeping systems to implement:
– Mandatory data collection and recordkeeping, and
– Performance measures specific to Additional/Accelerated
Actions
SHRIMP Implementation Plan
• Section B describes how user will implement
Additional/Accelerated Actions (if any*)
• *One common complaint from operators – Misperception
that plans must include at least one A/A Action
• No such presumption in the rule – if risks are low, no
additional actions are required
• Section C describes how user will implement
procedures to collect additional information needed to fill
gaps (if any -- Same misperception as above)
Revisions Under Development
• Create a mechanism to walk user through a
complete program re-evaluation and log
changes from previous plan
• Use the data from ~1,600 users (1/3 of the
industry) to improve the risk model
– Example: Is the user’s corrosion leaks/mile of
coated, CP steel higher, lower or statistically no
different from other SHRIMP users?
Improving the Risk Model
• Risk = Probability times Consequences
• SHRIMP model assigns weighting to probability
and consequence factors
• Based on SME judgment, not hard science
• Improvements include:
– Fixing known problems (e.g. Blasting)
– Using data from SHRIMP users
Data Mining of Current Users: Example
• Mann-Kendall test reports if there is an upward
trend in leaks/mile or /service
• Upward trend results in higher risk score
• But what if its not increasing, but is unacceptably
high
• Unfortunately, no such data available
• 0.092 corrosion leak repairs/mile of metallic
main (2010 Distribution Annual Reports)
Current User Data Example
External corrosion leaks per mile of main
0.092
Bare, No CP Bare CP Coated, No CP Coated CP
Average
0.5945
0.0546
0.2790
0.0131
Mean
1.8296
0.1802
1.2604
0.0346
Standard Error
0.9872
0.0824
0.9101
0.0054
Median
0.3015
0.0000
0.0505
0.0040
Mode
0.0000
0.0000
0.0000
0.0000
Standard Deviation
8.4922
0.8243
4.8156
0.1079
Risk Ranking Implications
• Systems or subsections of systems with
statistically higher or lower corrosion leak rates
will have probability scores bumped higher or
lower, respectively
• Similar analysis underway for other threats (e.g.
excavation damages/locate ticket)
• Also allowing users to compare with other userdefined peer groups (same state, similar size,
etc)
Big Change – The Plan Revision Process
• Rule requires complete plan re-evaluation at least once every 5
years – more often if risk characteristics change
• Next SHRIMP Revision will include:
– “Correct” – Can amend Plan text but not threat, risk, AA’s PM’s
(Becomes Version 1.1.2)
– “Revise” – Can amend Plan text and modify threat, risk, AA’s
PM’s, but doesn’t require revising/confirming everything
(Version 1.2.1)
– “Re-evaluate” – Sets all flags to “Incomplete.” Cannot create a
new plan until all threats, risk rankings, AA’s PM’s and
Implementation plans have been reviewed (Version 2.1.1)
Archiving Old Plans
• Whenever “Correct,” “Revise” or “Re-Evaluate” are
selected, a copy of the existing plan will be archived – no
further changes can be made to this plan
• All data (except certain Implementation Plan text) will be
copied into a new Plan
• User must complete the correct, revise or re-evaluate
process and generate a new plan before other actions
can be taken
• User selects effective date; SHRIMP assigns “Replaces
Plan dated”
Title Page – Revision Numbers and Dates
DISTRIBUTION INTEGRITY
MANAGEMENT PLAN
For Kastanasburg Utilities Revised
125 East Northwest Street, South
Kastanasburg, Tennessee 34567
Generated Date: 2012-07-15 Version: 2.1.2
Effective Date: 2012-08-02 Replaces Version:
2.1.1 Effective: (2011-08-02)
Revision History – User Entered
Revision Log – SHRIMP Generated
11.4.2. CHANGES TO RISK EVALUATION AND PRIORITIZATION
Overview
The following summarizes the differences in the risk ranking between
this version of the plan and the prior version.
Revision Log – SHRIMP Generated
11.4.3. CHANGES TO RISK BASED ADDITIONAL ACTIONS
Overview
The following lists the risk based additional/accelerated actions that
were added or removed for the risk sections in this version of the plan.
Revision Log – SHRIMP Generated
11.4.4. CHANGES TO RISK BASED PERFORMANCE MEASURES
Overview
The following lists the risk based performance measures that were
added or removed for the risk sections in this version of the plan.
Revision Log – SHRIMP Generated
11.4.1. CHANGES TO THEAT ASSESSMENTS
The following lists the risk based performance measures that were
added or removed for the risk sections in this version of the plan.
• Under Development
• Listing all changes proved too lengthy
• Will focus on only those changes that impacted
risk rankings or that created or eliminated
sections
Changes to Implementation Plan
• Since Implementation Plan is text, cannot log the
changes in as much detail as other sections
• Will require user to revisit and confirm
Implementation Plan.
• Will NOT copy over Implementation Plan text
describing user-selected Additional Actions and
Performance Measures – user must enter again
• Or may offer the option of copying
Other SIF Programs
•
•
•
•
•
•
“SHRIMP-like” Drug and Alcohol Plan
Operator Qualification
O&M Procedures for covered tasks
“SHRIMP-like” O&M Plan
Updating small operators’ guides
Go to www.apgasif.org for more info
Questions?