SHRIMP John Erickson PE APGA Security and Integrity

SHRIMP John Erickson, PE APGA Security and Integrity Foundation (SIF) August 22, 2012

What is the Security and Integrity Foundation? • 501 c 3 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 (Turbo. Tax) • 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 23 50 0 10 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 0. 092

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

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?