Post on 30-Dec-2015
1
DIMSAA Distribution Integrity
Management SME Approach
August – 2009
DIMSA
A Distribution Integrity Management SME Approach The Approach is predicated on
Program Performance Risk Management Programs currently being implemented are utilized to demonstrate
compliance / risk management
The Approach Includes The Written Plan Your Current Methodology for 49 CFR 192 Compliance Three Distribution Integrity Procedures
1. Program Performance Evaluation
2. Threat Specific Risk Management
3. Results Driven Improvement
This is NOT Transmission, so we will NOT treat it as such…
DIMSA Collaboration
SEMPRA Utilities SoCal Gas / San Diego Gas & Electric
Largest LDC in the country
PI Confluence Procedural Implementation Management (ICAM)
Manage Schedule Track Document Report
Your Operations
Would say your systems are safe and reliable?
Do you believe you are currently managing safety & reliability?
Are you in compliance with the requirements of 49 CFR 192?
Your Operations
Are you currently analyzing the results of your 49 CFR 192 compliance activities?
Can you correlate these results back to your incident / safety record?
Are you currently evaluating these analyses to determine the effectiveness of your programs?
Have you documented these analyses . Evaluations to support a defensible position that you are in fact managing safety & reliability?
The Premise In most cases the operators are doing the right things
to manage integrity In most cases the operators safety / reliability records
and excellent Implementing the requirements of 49 CFR 192
manages risk… It is all about demonstrating performance
Program Performance Risk Management
Programs Required by 49 CFR 192
Program Performance Risk Management Programs currently being implemented are utilized to
demonstrate risk management
Performance may be measured through the use of Key Performance Indicators (KPI)
KPI take two forms, leading and lagging Leading indicators refers to the measurement of the effort Lagging indicators refers to the measurement of the results
Program Performance Risk Management
Risk Evaluation / PrioritizationCorrosion
Risk Evaluation / PrioritizationExcavation
Risk Evaluation / PrioritizationOther Damage
Risk Evaluation / PrioritizationNatural Forces
Risk Evaluation / PrioritizationMaterial / Weld Failure
Risk Evaluation / PrioritizationEquipment Failure
Risk Evaluation / PrioritizationInappropriate Operations
Quote from Texas Railroad Commission
“Operators are sleep walking thru the rule”
They are performing the requirements of 192 They are capturing the required data They are NOT looking at the data They are not improving based on the results
Program Performance Risk Management
The Plan Objective State the company positions Formalize program descriptions Analyze and Evaluate program performance Correlate results to safety Take credit where credit is due Improve IF and WHERE necessary
Statistics
Over 91% of significant incidents are caused by other outside force damage, excavation damage and other causes.
PHMSA currently defines a significant pipeline incident as those reported by pipeline operators when any of the following conditions are met:
fatality or injury requiring in-patient hospitalization $50,000 or more in total costs, measured in 1984 dollars highly volatile liquid releases of 5 barrels or more or other liquid
releases of 50 barrels or more liquid releases resulting in an unintentional fire or explosion
Statistics
PHMSA Significant Incident Data 2008
2008 Gas Distribution Incident Causes
# of Significant Incidents
% of Total Significant Incidents
Other Outside Force Damage 45 43.69%All Other Causes 27 26.21%Excavation Damage 13 12.62%Natural Force Damage 8 7.77%Human Error 4 3.88%Material Failure 4 3.88%Corrosion 2 1.94%Total 103 100.00%
Damage of various types accounts for 65% of the significant incidents with all other causes adding another 26%.
PHMSA Reported Significant Incidents Nation Wide for 2008
43%
26%
13%
8%
4%4% 2%
Other Outside Force Damage
All Other Causes
Excavation Damage
Natural Force Damage
Human Error
Material Failure
Corrosion
Reality Check
SO WHAT THREAT SHOULD WE BE FOCUSING OUR ATTENTION ON???
The Various
Types of DAMAGE
Programs Required by 49 CFR 192
10 /17 Programs address Damage in one way or another
Leak Survey and Leak Prioritization Metallic Leak Repair Plastic Leak Repair Damage Prevention Public Awareness Pipeline Patrol Corrosion Control Land Movement Management Main and Service Replacement Bridge and Span Inspections
Programs Required by 49 CFR 192
EACH of these 10 programs includes risk based aspects that support program performance risk management
More frequent patrols in populated areas More frequent leak surveys in area with higher
consequence Repairs of leaks prioritized by consequence
Going Forward
How are you going to take what you are currently doing, formalize it, analyze it, evaluate it and then correlate it back to your safety record?
How are you going to demonstrate compliance and that your safety and reliability objectives are being met today?
How will these same objectives be met in the future?
A Program Performance Risk Management Approach
Program Performance Risk Management
The Written Plan is new
Programs are already being implemented
Analysis, Evaluation and Improvement is new
Program Performance Risk Management
The Written Plan will include sections that outline your position on each element of the rule
System Knowledge Threat Identification Risk Evaluation / Prioritization Actions to Address Risk Performance Measures Plan Effectiveness / Improvement Reporting
Program Performance Risk Management
A Different View of the Elements
However, Program Performance Risk Management takes a slightly different approach
Performance Measures are detailed prior to Risk Evaluation and Prioritization
Performance of the programs will be utilized to document that risk is being managed
Actions to Address Risk will be combined with Improvement These additional actions will be a means of improving the plan Plan improvement includes program modifications to enhance performance
Plan Effectiveness is rolled up into performance. Performance is the how we measure plan effectiveness through the
demonstration of risk management Performance against threats Performance against their associated consequences
System Knowledge
The Program Performance Risk Management approach includes formalized program descriptions which detail the data collected by each program and how this data supports an understanding of the system
Additionally, the position on System Knowledge will describe the existence of other data sets, such as historical records, that also demonstrate the operators knowledge of their system
Threat Identification
The Program Performance Risk Management approach includes formalized program descriptions which detail how each program supports the identification of various threats to the system and where in the system they have a higher probability
Threat Identification
DIM Programs Corrosion Natural ForcesExcavation
DamageOther Outside Force Damage
Material or Weld Failure
Equipment Malfunction
Inappropriate Operation
Leak Survey and Leak
Prioritization (Grading) [192.723] TI TI TI TI TI TI TI
Pipeline Patrol [192.721] TI TI TI TI
Plastic Pipe Management [192.59 and
192.311] TI
Bridge and Span Inspections [192.479 - 192.481] TI TI TI TI TI
Equipment Inspections [192.731 - 192.749] TI
Internal Operations Audit
[192.1007(f)] TI
Operator Qualifications
[Subpart N] TI
Drug and Alcohol [Part 199] TI
Threat Identification
DIM Programs Corrosion Natural ForcesExcavation
DamageOther Outside Force Damage
Material or Weld Failure
Equipment Malfunction
Inappropriate Operation
TI= Threat Identification 2 3 2 3 3 4 4
The Program Performance Risk Management approach takes advantage of the fact that, at a minimum, there are 2 - 4 programs utilized to identify each threat and the locations where they may have a higher probability.
Performance Measures
Performance may be measured through the use of Key Performance Indicators (KPI)
KPI take two forms, leading and lagging Leading indicators refers to the measurement of the effort Lagging indicators refers to the measurement of the results
The premise of a performance based approach is that if the efforts are defined so as to generate the optimal results, and these efforts are in fact implemented, then the desired results will be a byproduct
Performance Measures
The Quality Control Bill of Rights states that
The right person Will do the right job At the right time In the right place The right way In order to achieve the Right Results
Performance Measures
Required by the Rule Lagging
Measurement of Results
Optional to the Operator Leading
Measurement of Efforts Implementation Data Management Data Analysis Follow Up Actions Incident Mapping
Performance Measures
The basic implementation of EVERY program is the first and primary performance indicator.
If results indicate that performance of the program is not effective then the first analysis has to be … was the program properly implemented pursuant to its procedure
The programs must be properly implemented prior to the determination that any improvement might be required
Performance Measures
The Program Performance Risk Management approach requires that each program be defined in terms of its ability to provide leading and/or lagging performance indicators.
These indicators, when measured will be used to determine the effectiveness of each program in terms of its ability to manage threats and their associated consequences
Through the management of threats and their associated consequences, we will be successfully managing risk
Performance Measures
The programs required by or that may have been implemented in support of 49 CFR192 provide either leading or lagging indicators
DIM Programs KPI TriggersMetallic Leak Repair [192.309 and 192.703] Lagging Plastic Leak Repair [192.311 and 192.703] Lagging
Damage Prevention [192.614] Lagging Main and Service Replacement [192.311,
192.483 and 192.487] Lagging Internal Operations Audit [192.1007(f)] Lagging
Operator Qualifications [Subpart N] Lagging Drug and Alcohol [Part 199] Lagging
Emergency Planning [192.615] Lagging EFV Program [192.381] Lagging
Public Awareness [192.616] Leading Education
Pipeline Patrol [192.721] LeadingInspection / Survey
Land Movement Management [192.317] LeadingInspection / Survey
Corrosion Control [Subpart I] LeadingInspection / Survey
Plastic Pipe Management [192.59 and 192.311] Leading Repair
Bridge and Span Inspections [192.479 - 192.481] Leading Repair
Equipment Inspections [192.731 - 192.749] Leading RepairLeak Survey and Leak Prioritization
(Grading) [192.723] Leading / Lagging Repair
Performance Measures
Since leading indicator programs do not directly provide any measurable data that has value, their performance will be measured based on the actions they trigger.
DIM Programs KPI TriggersLeak Survey and Leak Prioritization
(Grading) [192.723] Leading / Lagging RepairPublic Awareness [192.616] Leading Education
Pipeline Patrol [192.721] LeadingInspection / Survey
Land Movement Management [192.317] LeadingInspection / Survey
Corrosion Control [Subpart I] LeadingInspection / Survey
Plastic Pipe Management [192.59 and 192.311] Leading Repair
Bridge and Span Inspections [192.479 - 192.481] Leading Repair
Equipment Inspections [192.731 - 192.749] Leading Repair
Performance Measures
For example – a line patrol may determine the there was recent excavation in an area. This discovery would lead to further inspection of the area or possibly a new leak survey to determine if the pipeline was damaged
The performance measure is how many times were these types of conditions discovered and how many times were they acted on
If it can be show that in100% of the cases, if conditions were discovered that indicated potential damage to the system, action was taken to mitigate, then the program is being proper implemented and the leading indicators favorable reflect performance
Performance Measures
Lagging indicator programs provide measurable data that has value and their performance will be measured based on these results.
For example – leak surveys allow us to determine the number of leaks, which is a lagging indicator because they already exist. One measure of the effectiveness of the integrity plan is whether this number is improving
The leak survey program also provides a leading indicator in that we are able to determine how many leaks found (grade 1 or 2) triggered the action of repair
If 100% of the grade 1 leaks are repaired immediately and 100% of the grade 2 leaks are addressed according to policy, then the leading performance indicator would suggest that the program was effective AND if the number of leaks by grade was trending downward, then the lagging performance indicator would suggest that the program was effective
Performance Measures
In ALL cases, these performance measures may be utilized to manage threats or their associated consequences.
For example – by providing the leak grade information the leak surveys allow us to manage the consequences since by definition the grade is a function of the nature of the release
Regardless of the threat that may have contributed to the leak, the grading system allows us to trigger repairs.
These repairs allow us to determine and manage the root cause threat
Performance Measures
Program Performance Risk Management begins with the evaluation of each program in terms of its effectiveness in managing specific threat and/or their associated consequences.
For each program the leading and lagging indicators will be defined and measured
The measurements will weighted in relation to the program and threat where applicable
On a program by program basis, the performance measures will be utilized to rank the program effectiveness in addressing each threat
The following table shows each program and the threats and/or consequences it manages
Performance Measures
DIM Programs CorrosionNatural Forces
Excavation Damage
Other Outside Force
Damage
Material or Weld
FailureEquipment Malfunction
Inappropriate Operation
Public Awareness [192.616] CM TM / CM TM / CM CM
Pipeline Patrol [192.721] TM TM TM TM TM TM TM
Land Movement Management [192.317] TM / CM Plastic Pipe Management [192.59 and 192.311] TM Bridge and Span Inspections [192.479 - 192.481] TM TM Equipment Inspections [192.731 - 192.749] TM
Corrosion Control [Subpart I] TM Leak Survey and Leak Prioritization (Grading) [192.723] CM CM CM CM CM CM CMMetallic Leak Repair [192.309 and 192.703] TM TM TM TM TM TM TMPlastic Leak Repair [192.311 and 192.703] TM TM TM TM TM
Damage Prevention [192.614] TM TM Main and Service Replacement [192.311, 192.483 and 192.487] TM TM
Internal Operations Audit [192.1007(f)] TM
Operator Qualifications [Subpart N] TM
Drug and Alcohol [Part 199] TM
Emergency Planning [192.615] CM
EFV Program [192.381] CM CM
Risk Evaluation / Prioritization
The Program Performance Risk Management approach includes formalized program descriptions which detail how each program is being utilized to manage specific threats and the consequences associated with a failure whose root cause was that threat.
The management of threats and their consequences, supports the management of risk, with the objective being to demonstrate the safety and reliability of the system.
Risk Evaluation / Prioritization
Risk is managed, on a threat by threat basis relative to the specific areas where the program data substantiates that the probabilities are higher and/or the consequences are greater
If You Manage Threats & If You Manage Consequences….
You are Managing Risk
Risk Evaluation / PrioritizationDIM Programs Corrosion Natural Forces Excavation Damage
Other Outside Force Damage
Material or Weld Failure Equipment Malfunction
Inappropriate Operation
Public Awareness [192.616] CM TM / CM TM / CM CM
Pipeline Patrol [192.721] TM TM TM TM TM TM TM
Land Movement Management [192.317] TM / CM
Plastic Pipe Management [192.59 and 192.311] TM
Bridge and Span Inspections [192.479 - 192.481] TM TM
Equipment Inspections [192.731 - 192.749] TM
Corrosion Control [Subpart I] TM
Leak Survey and Leak Prioritization (Grading) [192.723] CM CM CM CM CM CM CM
Metallic Leak Repair [192.309 and 192.703] TM TM TM TM TM TM TM
Plastic Leak Repair [192.311 and 192.703] TM TM TM TM TM
Damage Prevention [192.614] TM TM
Main and Service Replacement [192.311, 192.483 and 192.487] TM TM Internal Operations Audit [192.1007(f)] TM
Operator Qualifications [Subpart N] TM
Drug and Alcohol [Part 199] TM
Emergency Planning [192.615] CM
EFV Program [192.381] CM CM
Risk Evaluation / Prioritization
DIM Programs Corrosion Natural Forces Excavation Damage
Other Outside Force Damage
Material or Weld Failure
Equipment Malfunction
Inappropriate Operation
TM= Threat Management 5 4 5 6 5 3 6
CM= Consequence Management 1 4 3 3 1 2 1
The Program Performance Risk Management approach is predicated on the fact that there are, at a minimum 3 - 6 programs utilized to manage each threat and 1-4 programs utilized to manage the associated consequences of these threats.
Risk Evaluation / Prioritization
Risk Management is demonstrated by through the aggregated evaluation of each program performance metric as it applies to any given threat. Total threat score is determined Performance is measured on the threat score range for the
specific threat Improvement is driven by the results
No review / improvement required Consider review / improvement Review / improvement required
Implement Improvement Procedure
Address Risk
Considering the fact that the Program Performance Risk Management is program centric, the contention is that the programs themselves are currently managing risk
Address Risk
The program performance evaluation results will serve as the drivers for both Additional Actions as well as Improvement
These additional actions / improvement may include Plan Improvement Program Improvement Physical Improvement Regulatory Improvement
Plan Improvement
The Plan will be reviewed for effectiveness Modify Positions
Update approach Update policy Update requirements by states or feds
Modify Programs Data Gathering Requirements Frequency Procedure
Modify Procedures Program Performance Evaluation Risk Management Improvement
Program Improvement
Program Improvement – as required existing programs may be modified. These modifications may be made to any of the aspects of the formal description detailed in the next section. However, the expected modifications if any will be primarily in terms of the frequency and the data collected. A secondary change might be the means by which the data is managed so that for example, we can further delineate the drivers for what has been categorized as “Other Damage” in the past.
New Program Creation – in the event it is determined that new programs are required to support the Utilities ability to manage risk, these programs will be designed, approved by management, documented and added to the Plan with change manage records documented.
Physical Improvement
System Change – Performance on the results of the analysis of the resultant data from the Programs currently being implemented, the best resolution to the management of specific threats may require system changes. Such changes are currently being evaluated and proposed through the Main and Service Replacement Program. In the event other system changes are required, a change management process will be followed to ensure the implications were considered, the appropriate approvals were granted, that the change was documented and finally, that the Plan was updated accordingly.
One Off Mitigation – in the event the annual analysis of the data provided through the various programs currently being implemented suggests that any area fall outside the norm in terms of risk, the Utilities will address each of these on an as needed basis. This may include mitigation of a specific threat though one time enhancement to the programs that manage this threat and/or its consequences, or it may include taking actions that heretofore have not been part of any program in place. If these one off mitigations are required and they are not part of any existing program, consideration will be made as to whether the creation of a new program is in order.
Regulatory Involvement
Regulatory Involvement – the commitment to be involved in all regulatory events. This includes active participation in industry forums such as SGA, AGA and GPTC. Additionally, all State and/or Federal public forums will be attended. It is the your position that as an LDC with an exemplary safety record, you can set examples for industry and serve a thought leaders in terms of their ability to safely manage their distribution integrity systems.
Reporting
External DOT Annual Revised DOT
Internal Performance Improvement Change Management
Program Descriptions
The Program Performance Risk Management approach includes formalized program descriptions for each of the programs being implemented. These descriptions, at a minimum will include:
Roles & Responsibilities Personnel Qualifications Procedures System Knowledge Support Threat Identification Threat Management Consequence Management Effectiveness Measures
Program Performance Risk Management
A Distribution Integrity Management SME Approach The Approach is predicated on
Program Performance Risk Management Programs currently being implemented are utilized to demonstrate
compliance
The Approach Includes The Written Plan Your Current Methodology for 49 CFR 192 Compliance Three Distribution Integrity Procedures
1. Program Performance Evaluation
2. Threat Specific Risk Management
3. Results Driven Improvement
Plan Implementation
Program Performance Evaluation Program specific analysis for threat / consequence management Each program is analyzed to determine its effectiveness in managing the various
threats and associated consequences
Prioritized Risk Management Threat specific program management Each threat is analyzed to determine the effectiveness of the various programs
that manage it in some fashion
Results Driven Improvement Program objectives being met Risk being managed
ICAM is a web based application that supports the management, scheduling, tracking, documenting and reporting of your distribution integrity procedures.
ICAM does not deal with numerical data; rather, it captures who, what, when, where and why.
ICAM provides decision based routing, notifications, management visibility and performance measures against program objectives.
From a business perspective ICAM ensures program sustainability, protects against workforce attrition and supports knowledge continuity.
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Questions?
gwhite@piconfluence.com
713-520-5050