WEBVTT 00:00:02.140 --> 00:00:05.280 I have 9:01 on my on my clock. So I'm just 00:00:05.280 --> 00:00:10.050 gonna go ahead and get started. My name is Isaac Monreal. 00:00:10.060 --> 00:00:12.570 I'm with the Texas Railroad Commission Pipeline Safety 00:00:12.570 --> 00:00:15.839 Division. And today we're gonna be talking about 00:00:15.849 --> 00:00:19.120 distribution integrity management. What we like to 00:00:19.120 --> 00:00:22.239 most affectionately called DIM. 00:00:22.239 --> 00:00:25.170 So just to kind of cover a couple of housekeeping items. 00:00:25.179 --> 00:00:29.620 Just so everyone is well aware is that 00:00:29.629 --> 00:00:31.730 this PowerPoint presentation is going to be available 00:00:31.730 --> 00:00:35.890 for download at this link showing on the screen. 00:00:35.899 --> 00:00:38.109 And just so everyone knows so you won't be scrambling 00:00:38.109 --> 00:00:41.659 to writing this down. It is going to be a copy of 00:00:41.659 --> 00:00:44.159 this link is going to be in the Q&A section 00:00:44.539 --> 00:00:48.460 showing on the bottom of your screen. And I would 00:00:48.460 --> 00:00:50.810 also like to encourage you all if you have any questions 00:00:50.820 --> 00:00:53.590 throughout the presentation feel free to use that Q&A 00:00:53.590 --> 00:00:56.689 We do have people on standby that that will 00:00:56.689 --> 00:00:59.329 be answering questions throughout the whole entire 00:00:59.329 --> 00:01:03.759 presentation so please feel free to to utilize that. 00:01:04.640 --> 00:01:08.969 So today we're gonna be talking about the framework 00:01:08.969 --> 00:01:13.480 of the DIM program as required by 192 or the minimum 00:01:13.480 --> 00:01:17.290 code of federal regulations part 192, 1000 series. 00:01:17.299 --> 00:01:20.709 How to build a DIM program, common mistakes that we've 00:01:20.709 --> 00:01:24.670 seen out in the field. The facility replacement program 00:01:24.670 --> 00:01:27.650 and how that ties in with the distributiontary management 00:01:28.040 --> 00:01:31.659 And I want to expect from whenever you have an inspection. 00:01:32.540 --> 00:01:34.840 So to kind of start off with the framework of a DIMP 00:01:34.840 --> 00:01:39.930 program. This this comes from the minimum code of 00:01:39.930 --> 00:01:46.049 federal relations part 192, the 1000 series 00:01:46.049 --> 00:01:49.540 essentially. And the best way of really breaking 00:01:49.540 --> 00:01:52.430 it all down is I always like to put it in steps 00:01:52.430 --> 00:01:56.980 and this is kind of something that is pretty 00:01:56.980 --> 00:02:00.239 throughout the, whenever you have like a DIMP inspection 00:02:00.239 --> 00:02:03.799 or whenever you, we like, I like to break everything 00:02:03.799 --> 00:02:06.310 down into the different sections. So whenever you, 00:02:06.310 --> 00:02:08.569 if you break everything down, you kind of have, you 00:02:08.569 --> 00:02:13.060 kind of have seven different distinct that with a DIMP program 00:02:14.039 --> 00:02:16.400 as shown on the screen, and we're gonna go through 00:02:16.400 --> 00:02:20.189 all of these individually pretty thoroughly. So 00:02:20.189 --> 00:02:23.300 you kind of start off with the first step is a knowledge 00:02:23.300 --> 00:02:27.699 of system. Whatever you were looking at your distribution 00:02:27.699 --> 00:02:31.879 integrity management if you can answer some basic 00:02:31.879 --> 00:02:35.050 simple questions, you're at the very least meeting 00:02:35.050 --> 00:02:38.150 the intent of code and you're pretty much and 00:02:38.150 --> 00:02:40.210 you're pretty much meeting the intent for that particular 00:02:40.210 --> 00:02:42.860 section. So for the first one is knowledge of system. 00:02:42.860 --> 00:02:45.330 So the question to be asking yourself here is what 00:02:45.330 --> 00:02:48.979 do you have? Can you define your system through like 00:02:48.979 --> 00:02:52.939 map or demarcation valves from start to finish, what 00:02:52.939 --> 00:02:56.370 is your jurisdiction? From the city gate coming in from 00:02:56.370 --> 00:02:58.210 the transmission lines coming in from the city gate 00:02:58.219 --> 00:03:00.699 all the way to every single meter. 00:03:00.699 --> 00:03:03.469 And everything in between. So like all of the 00:03:03.469 --> 00:03:06.759 valves. What you really want to know is what you 00:03:06.759 --> 00:03:10.469 have and where you have it. So that's kind of what 00:03:10.469 --> 00:03:14.729 the knowledge of system is really all about. Now 00:03:14.729 --> 00:03:17.560 the next step is what's called identified threats, 00:03:18.039 --> 00:03:20.219 so identify threats. The question you want to be asking 00:03:20.219 --> 00:03:22.060 yourself is, what type of problems are you having? 00:03:22.639 --> 00:03:25.919 So PHMSA or the pipeline hazardous materials 00:03:25.919 --> 00:03:29.330 safety administration, they like to categorize 00:03:29.340 --> 00:03:32.860 all the different threat categories. So things that 00:03:32.860 --> 00:03:35.310 gives you the threat categories, and a lot of these 00:03:35.310 --> 00:03:40.729 are gonna be very familiar and that you can and 00:03:40.729 --> 00:03:44.250 will see in terms of like say on your annual reports, 00:03:44.259 --> 00:03:46.659 they're all using the same terminology here. 00:03:47.139 --> 00:03:50.349 So PHMSA on their website also defines every single 00:03:50.349 --> 00:03:51.949 one of these. So I would encourage you to go and look 00:03:51.949 --> 00:03:56.789 at the website. So for when you're doing, when 00:03:56.789 --> 00:04:00.199 you're establishing a DIMP program, and you're 00:04:00.210 --> 00:04:03.069 looking at all the these different threat categories, 00:04:03.080 --> 00:04:06.689 you do have an option of sub categorizing. So sometimes 00:04:06.689 --> 00:04:08.889 whenever you have, say like a leak and you're trying 00:04:08.889 --> 00:04:12.120 to, and you want to really like further go down into 00:04:12.120 --> 00:04:15.439 the granular details. You can and do have the option 00:04:15.439 --> 00:04:18.750 to sub categorize, a good example of this is corrosion. 00:04:18.759 --> 00:04:23.250 You have external and internal atmospheric corrosion 00:04:23.329 --> 00:04:26.420 that you can, if you elect to subcategories, you 00:04:26.420 --> 00:04:31.800 don't have to, but you can. Now, another one, the 00:04:31.800 --> 00:04:35.410 next step in the program it would be evaluating ranking 00:04:35.410 --> 00:04:37.600 risk. So the question you want to be asking yourself 00:04:37.600 --> 00:04:40.509 is of all the different threat categories that you 00:04:40.509 --> 00:04:43.209 have established what is your biggest problem? What 00:04:43.209 --> 00:04:45.959 is the number one? What is your number 2? The 00:04:45.959 --> 00:04:49.199 idea here is that you're supposed to rank all of the 00:04:49.199 --> 00:04:53.129 identified threats of the eight categories. Or if like 00:04:53.129 --> 00:04:56.769 say you subcategorize from what we were talking 00:04:56.769 --> 00:04:59.500 about before with like the corrosion, you still have 00:04:59.500 --> 00:05:02.589 to rank all of the sub categories as well. So it will 00:05:02.589 --> 00:05:05.759 be a minimum of eight rankings. If not, if you have 00:05:05.759 --> 00:05:09.209 more than you can, like say, you can go up to 00:05:09.209 --> 00:05:13.810 16. I've seen up to 36 threat categories. I mean 00:05:13.810 --> 00:05:17.759 you want to rank all of them. Now that said you 00:05:17.759 --> 00:05:24.839 can also subdivide your system itself. So I'll do 00:05:24.839 --> 00:05:27.199 this in two different examples. The first example is 00:05:27.209 --> 00:05:31.879 if let's just say you just wanna use just regular subcategories 00:05:31.889 --> 00:05:35.259 or regular primary categories and you're gonna be ranking 00:05:35.259 --> 00:05:39.980 all of your threats. So this is a good example of what 00:05:39.980 --> 00:05:42.639 it would look like saying the number one ranked threat 00:05:42.649 --> 00:05:49.079 is um excavation damage. Now one thing to know as uh 00:05:49.089 --> 00:05:52.149 as I said you have to rank every single one of your 00:05:52.160 --> 00:05:55.629 your threat categories. Um One of the third category 00:05:55.639 --> 00:05:58.839 is other concerns. One thing that we have seen and 00:05:58.839 --> 00:06:01.560 one thing we always like to point out is that for other 00:06:01.939 --> 00:06:04.560 Is we like to shy away from it as much as possible 00:06:04.560 --> 00:06:06.720 The vast majority of the time you can categorize them 00:06:06.720 --> 00:06:09.410 into all the other threat categories that pretty thorough 00:06:09.420 --> 00:06:11.930 and look at the definitions but anything more than 00:06:11.930 --> 00:06:14.420 like say 10% is something that is going to catch our 00:06:14.420 --> 00:06:20.310 attention. So now the other example of evaluating ranking 00:06:20.310 --> 00:06:23.660 risk would be if you subdivide your system into say 00:06:23.670 --> 00:06:25.480 to different parts of town. So let's say you have a 00:06:25.480 --> 00:06:28.310 north part of town in south part of and they're so 00:06:28.310 --> 00:06:32.259 different in y'all's eyes that you want to that you 00:06:32.259 --> 00:06:37.350 electing to um subdivide your whole entire system so 00:06:37.350 --> 00:06:40.610 that is perfectly acceptable and you're more than welcome 00:06:40.610 --> 00:06:43.680 to do that. Just note that if you do subdivide your 00:06:43.680 --> 00:06:46.790 system then you have to rank twice. So this is a good 00:06:46.790 --> 00:06:49.449 example of the saying you're going to be the north 00:06:49.449 --> 00:06:52.550 part of town that you're going to be uh ranking on 00:06:52.550 --> 00:06:55.420 all of your risk, say your number one ranked is risk 00:06:55.420 --> 00:06:57.560 in this particular case will be equipment failure. 00:06:57.639 --> 00:07:01.000 And then um subsequently that if you do yourself part 00:07:01.000 --> 00:07:05.139 of town you re rank all of your risk as well. So 00:07:05.139 --> 00:07:08.370 keep keep in mind that if you do um subcategories or 00:07:08.370 --> 00:07:11.089 threats, so you have 16 threat categories that means 00:07:11.089 --> 00:07:14.660 that you're gonna have to send rank the risk twice 00:07:15.139 --> 00:07:18.589 For 16 distinct categories on behind your north side 00:07:18.589 --> 00:07:21.060 and 16 categories on your south side if you like to 00:07:21.069 --> 00:07:23.139 use. 00:07:23.139 --> 00:07:26.240 So next, the next step is to identify and implement 00:07:26.240 --> 00:07:28.769 measures to address. Of course you want to be asking 00:07:28.769 --> 00:07:33.079 yourself here is um of of your biggest problem, what 00:07:33.079 --> 00:07:36.339 are you gonna do about it? Um One thing that we always 00:07:36.339 --> 00:07:39.680 like to always like to encourage people is especially 00:07:39.680 --> 00:07:42.230 this particular step is that you want to give yourself 00:07:42.230 --> 00:07:46.100 credit for what you do. So if you go above and beyond 00:07:46.100 --> 00:07:50.800 code, if you go and uh put an extra barricade that 00:07:50.800 --> 00:07:52.610 is not required by code but you want to do but you 00:07:52.610 --> 00:07:54.639 want to do it to protect your system a little bit better 00:07:54.649 --> 00:07:57.420 You want to give yourself credit for what you're doing 00:07:57.420 --> 00:07:59.480 and this is this is where you want to give yourself 00:07:59.480 --> 00:08:03.910 credit, this is that that particular stuff. So a good 00:08:03.910 --> 00:08:07.069 example of this would be is let's just say we use an 00:08:07.069 --> 00:08:10.269 example of excavation damage being the number one ranked 00:08:10.279 --> 00:08:13.610 ranked threat and you want to go above and beyond and 00:08:13.610 --> 00:08:17.850 say well I want to curve the my excavation damage and 00:08:17.850 --> 00:08:20.300 and try to get to go down. So You know above and 00:08:20.300 --> 00:08:23.189 beyond and say well I'm going to put a booth in high 00:08:23.189 --> 00:08:27.959 school football game to promote 811 and to try to see 00:08:27.959 --> 00:08:30.560 if we can get the third party damage and really get 00:08:30.560 --> 00:08:33.129 the word out and trying to see if we can lower this 00:08:33.129 --> 00:08:36.279 is where you want to give yourself credit. For. Another 00:08:36.279 --> 00:08:39.700 good example of this would be um if you want to increase 00:08:39.700 --> 00:08:43.320 the frequencies code requires you to periodically love 00:08:43.320 --> 00:08:45.590 and look at atmospheric corrosion within your system 00:08:45.600 --> 00:08:48.470 Um, if you want to increase those frequencies, that's 00:08:48.470 --> 00:08:51.639 another way of doing. But all in all the best way, 00:08:51.639 --> 00:08:54.159 the best thing that you want to do is give yourself 00:08:54.159 --> 00:08:56.470 credit for what you're doing and document what you're 00:08:56.470 --> 00:08:59.970 doing and document document, document, document. I 00:08:59.970 --> 00:09:02.049 can't stress that enough is the best thing that y'all 00:09:02.049 --> 00:09:05.009 that y'all can be doing is document everything that 00:09:05.009 --> 00:09:08.940 you're doing for for this particular stuff. 00:09:08.940 --> 00:09:12.129 So the next step is going to be measured performance 00:09:12.129 --> 00:09:17.009 monitor results in designated. So if from what you're 00:09:17.009 --> 00:09:18.460 doing, like, let's say you went to the high school 00:09:18.460 --> 00:09:22.320 football games, you put a booth out there. And the 00:09:22.330 --> 00:09:24.539 question to be asking yourself here is, did it work 00:09:24.549 --> 00:09:28.940 is what you're doing, working and reducing risk. Um 00:09:28.950 --> 00:09:32.580 This is also the step that talks about where you want 00:09:32.580 --> 00:09:35.899 to monitor your results in particular, like your baseline 00:09:35.899 --> 00:09:39.360 results. So this is kind of really an important distinction 00:09:39.360 --> 00:09:42.860 that I really like to spend a little bit of clarify 00:09:43.240 --> 00:09:47.429 So a baseline for the terminology wise, baseline for 00:09:47.429 --> 00:09:49.820 distribution integrity management really talks about 00:09:49.820 --> 00:09:52.559 performance baseline for each performance measures 00:09:53.139 --> 00:09:58.899 So the difference is with if you're coming or coming 00:09:58.899 --> 00:10:01.730 from the transmission side, baseline is very different 00:10:01.730 --> 00:10:05.690 from the, from transmission baseline, how it works 00:10:05.690 --> 00:10:09.590 in in in dem is typically a year or a series of 00:10:09.590 --> 00:10:15.019 years that an operator establishes. Um for each performance 00:10:15.019 --> 00:10:18.309 measures. Now there are technically six mandatory performance 00:10:18.309 --> 00:10:23.750 measures, five most readily used. And for those, for 00:10:23.750 --> 00:10:27.309 those of you, all using the simple handy risk basement 00:10:27.320 --> 00:10:30.950 integrity management plan, what we call shrimp trump 00:10:30.950 --> 00:10:33.289 does not do baseline for you. It's kind of one of those 00:10:33.289 --> 00:10:36.220 things where it gives you guidance on how to do it 00:10:36.220 --> 00:10:38.950 but it doesn't actually do it for you. So let's kind 00:10:38.950 --> 00:10:42.759 of go over a couple of uh, of the fine mandatory ones 00:10:43.139 --> 00:10:45.519 and some of these are gonna be very familiar onto, 00:10:45.519 --> 00:10:48.679 y'all if y'all are doing the annual reports and um 00:10:48.690 --> 00:10:51.250 there the number of leaks either eliminated or repaired 00:10:51.250 --> 00:10:55.110 categories by cause their excavation damage is an american 00:10:55.149 --> 00:10:57.940 production tickets. 00:10:57.940 --> 00:11:00.200 The total number of leaks either eliminate or repaired 00:11:01.539 --> 00:11:05.259 categorized by cause the total, the number of hazardous 00:11:05.259 --> 00:11:07.950 leaks either eliminate or repair to categorize by material 00:11:07.950 --> 00:11:09.980 Now, the fifth one is kind of important and I like 00:11:09.980 --> 00:11:12.200 to emphasize this one a little bit more because that 00:11:12.200 --> 00:11:17.039 is the one mandatory performance measure that is required 00:11:17.039 --> 00:11:22.500 by code that is not on your annual report. So for those 00:11:22.500 --> 00:11:25.450 of you who can, you can easily just go back and look 00:11:25.450 --> 00:11:28.850 up what you're different performance measures are For 00:11:28.850 --> 00:11:30.799 the mandatory performance measures at the very least 00:11:30.809 --> 00:11:33.610 But the 5th 1 isn't, that one isn't on your annual 00:11:33.610 --> 00:11:35.990 report. So that was something you have to really make 00:11:35.990 --> 00:11:37.850 sure that you're doing because we have some people 00:11:37.909 --> 00:11:40.929 all on that. And the next one is any additional measures 00:11:40.929 --> 00:11:45.279 and that, y'all, Dean, if you do do put something as 00:11:45.289 --> 00:11:48.100 uh, like additional measures that you really want to 00:11:48.100 --> 00:11:51.480 put on there to measure performance bombings, uh, like 00:11:51.490 --> 00:11:55.909 we do encourage you all to do so. So, a good example 00:11:55.909 --> 00:11:59.320 of this one would be, um, excavation tickets is the 00:11:59.320 --> 00:12:02.440 easiest one on them that I can come up with. It's really 00:12:02.440 --> 00:12:05.669 easy. It's really easy to kind of look at from the 00:12:05.669 --> 00:12:09.720 standpoint. So let's just say in 2016, you start your 00:12:09.720 --> 00:12:15.080 program and you establish your baseline with 2,145 00:12:15.090 --> 00:12:19.210 excavation take. So you are required to look at these 00:12:19.210 --> 00:12:23.480 year by here and kind of keep track of this and um 00:12:23.490 --> 00:12:27.740 uh, Every single year. So let's just say in 2018, you 00:12:27.740 --> 00:12:30.840 kind of have a spike in um, numbers. If you're kind 00:12:30.840 --> 00:12:33.980 of looking at my example here and you go from like 00:12:33.990 --> 00:12:39.169 2000s and you spike up to 3000. So one thing that that 00:12:39.169 --> 00:12:42.600 we, we always like to encourage and you are required 00:12:42.600 --> 00:12:44.549 to do is, you're gonna be able to, you're going to 00:12:44.549 --> 00:12:47.080 have to be able to explain the trends and some of them 00:12:47.080 --> 00:12:50.070 can be very very simple and of saying, well why did 00:12:50.070 --> 00:12:53.860 you have a spike in 2018 in this particular example 00:12:54.539 --> 00:12:56.759 But you are going to have to be able to explain them 00:12:57.139 --> 00:13:02.460 So the next step would be periodic evaluation and improvement 00:13:03.240 --> 00:13:06.330 The question you might be asking yourself is your overall 00:13:06.330 --> 00:13:10.320 program working and this is from start to finish, from 00:13:10.330 --> 00:13:13.419 your knowledge of system all the way all the way to 00:13:13.419 --> 00:13:17.389 your documentation and you're monitoring results from 00:13:17.389 --> 00:13:19.909 start to finish. What is your program working now? 00:13:19.919 --> 00:13:22.289 Code specifically says the operator must conduct a 00:13:22.289 --> 00:13:26.450 complete program re evaluation at least every five 00:13:26.450 --> 00:13:29.620 years. Now. You are you are allowed to do it sooner 00:13:29.620 --> 00:13:33.720 and we do encourage you all to do it sooner. Um but 00:13:33.720 --> 00:13:36.330 the idea here is that you have to basically go back 00:13:36.330 --> 00:13:39.120 to step one and walk through each one of the steps 00:13:39.129 --> 00:13:42.799 and in particular that you're looking at your rerunning 00:13:42.799 --> 00:13:46.759 the risk model that you are um from start to finish 00:13:46.759 --> 00:13:49.830 you are doing every single step and really looking 00:13:49.830 --> 00:13:55.179 at every single step and the last a good example of 00:13:55.179 --> 00:13:57.759 this one uh kind of like I was saying the same before 00:13:57.759 --> 00:14:01.090 you do wanna rerun your risk model. You wanna when 00:14:01.090 --> 00:14:02.909 you're walking through each one of these steps, you 00:14:02.909 --> 00:14:06.950 also want to update all all all information. Like if 00:14:06.950 --> 00:14:09.850 you have a new director, if you have any people responsible 00:14:09.850 --> 00:14:12.029 for for the program, you don't want to be updating 00:14:12.029 --> 00:14:16.639 your your program, your procedures. Um and uh and take 00:14:16.639 --> 00:14:20.279 appropriate steps to address certain changes as you 00:14:20.289 --> 00:14:23.789 as a program starts to mature when especially when 00:14:23.789 --> 00:14:28.470 you actually rerun your model. If you are doing are 00:14:28.480 --> 00:14:33.490 taking steps to mitigate risk. And naturally those 00:14:33.490 --> 00:14:35.509 risks for that particular threat category should go 00:14:35.509 --> 00:14:38.190 down. So when you rerun your risk model you're going 00:14:38.190 --> 00:14:43.080 to be looking naturally looking at new things. So uh 00:14:43.090 --> 00:14:45.649 you should be taking different different steps to address 00:14:45.649 --> 00:14:48.240 those changes. 00:14:48.240 --> 00:14:51.759 And the last step is going to be reporting results 00:14:51.759 --> 00:14:57.330 This is also the step that uh you want to be giving 00:14:57.330 --> 00:15:00.049 yourself credit for what you're doing. Um One thing 00:15:00.049 --> 00:15:05.990 to kind of realize is that uh whenever you're keeping 00:15:06.000 --> 00:15:12.259 documentation for um for dim it's when the way it works 00:15:12.259 --> 00:15:17.080 is when last used that particular document. So let's 00:15:17.080 --> 00:15:20.919 just say you have a document that is five years old 00:15:20.919 --> 00:15:23.149 and you still you're still using it as part of your 00:15:23.149 --> 00:15:27.659 risk analysis. And if you last used it five years ago 00:15:27.669 --> 00:15:31.950 that's when the clock starts. So theoretically on that 00:15:31.950 --> 00:15:35.330 particular document. Could could go up to 15, sometimes 00:15:35.330 --> 00:15:39.409 20 years old on how long the document has originally 00:15:39.409 --> 00:15:46.000 been uh Um then existing but it stops the clock for 00:15:46.000 --> 00:15:49.350 the 10 year starts when you last used it. So just kind 00:15:49.350 --> 00:15:53.309 of keep that, keep that in mind. I can't stress documentation 00:15:53.309 --> 00:15:55.440 enough document, document, document, if you didn't 00:15:55.440 --> 00:15:58.279 do it, it never happened. And we always like to encourage 00:15:58.279 --> 00:16:00.159 saying give yourself credit for it to doing the vast 00:16:00.159 --> 00:16:03.080 majority of time. We've seen that a lot of operators 00:16:03.080 --> 00:16:04.899 are doing the right thing, they want to do the right 00:16:04.899 --> 00:16:06.700 thing, they're just not giving themselves credit for 00:16:06.700 --> 00:16:09.929 what they're doing. So please please please document 00:16:09.929 --> 00:16:13.070 as much as much as you possibly can. So to kind of 00:16:13.070 --> 00:16:16.129 summarize all the different steps this it's knowledge 00:16:16.129 --> 00:16:19.429 of system identified threats, evaluating uh evaluating 00:16:19.429 --> 00:16:22.529 rank risks, identifying implement measures to address 00:16:22.529 --> 00:16:26.340 risks, um measure performance, monitor results in madame 00:16:26.340 --> 00:16:30.820 effectiveness, pr uh evaluation improvement and reporting 00:16:30.820 --> 00:16:34.289 results. So the next topic that we're gonna be talking 00:16:34.289 --> 00:16:38.360 about is building a jump program. So after you go through 00:16:38.360 --> 00:16:40.600 some of these steps, these are this is going to be 00:16:40.600 --> 00:16:43.340 kind of like uh the things that you want to be looking 00:16:43.340 --> 00:16:45.889 for when you're building. So the best analogy that 00:16:45.889 --> 00:16:49.100 I can come up with is building a dent program is like 00:16:49.100 --> 00:16:52.379 building a house you wanted. Like everything builds 00:16:52.379 --> 00:16:56.720 upon each other and and and everything supports one 00:16:56.720 --> 00:16:59.700 another. And if you do, if you mess up on on some 00:16:59.700 --> 00:17:02.370 of some of the steps early on, it's gonna be, you're 00:17:02.370 --> 00:17:05.329 gonna be really hard pressed to kind of make it work 00:17:05.329 --> 00:17:07.359 especially when it comes to some of the later step 00:17:08.039 --> 00:17:13.750 So the first, the first step obviously is uh, knowledge 00:17:13.750 --> 00:17:16.759 a system that really is your, your base foundation 00:17:17.140 --> 00:17:20.049 So whenever you're setting up a pro your gym program 00:17:20.049 --> 00:17:22.180 you really need to know what you have and where you 00:17:22.180 --> 00:17:26.720 have from start to finish from the city gate all the 00:17:26.720 --> 00:17:30.839 way to all the meter sets from like the mains and services 00:17:30.839 --> 00:17:33.339 and everything from that because that is your foundation 00:17:33.339 --> 00:17:35.789 you need to know what you have and where you have it 00:17:35.799 --> 00:17:40.839 And one thing that that you want to do is gather as 00:17:40.839 --> 00:17:44.700 much information from your service text before before 00:17:44.700 --> 00:17:48.960 it's too late. One thing that we have seen is uh, a 00:17:48.960 --> 00:17:51.670 lot of operators are starting to have aging populations 00:17:52.039 --> 00:17:56.150 and uh, we're starting to see a lot of people retire 00:17:56.160 --> 00:17:59.720 and they're taking a lot of experience out. So it's 00:17:59.720 --> 00:18:04.140 best to really gather all of that information. Uh as 00:18:04.140 --> 00:18:07.470 quickly as you can document, like have very thorough 00:18:07.470 --> 00:18:11.809 maps is the best thing that you can do and just kind 00:18:11.809 --> 00:18:15.579 of make sure that like uh that you are talking to all 00:18:15.579 --> 00:18:18.970 of your service text, you're talking to all of the 00:18:18.980 --> 00:18:21.220 boots on the ground to make sure that all of your maps 00:18:21.220 --> 00:18:23.769 and documents are complete and accurate as possible 00:18:24.440 --> 00:18:28.150 One thing I always like to say is that y'all are the 00:18:28.160 --> 00:18:31.410 smes for your system, especially your texts are the 00:18:31.410 --> 00:18:33.950 smes for your system for the simple fact that they're 00:18:33.950 --> 00:18:36.660 out there every single day and looking looking at looking 00:18:36.660 --> 00:18:38.960 at where all of the valves are knowing where everything 00:18:38.960 --> 00:18:43.079 is, knowing your system and you want to retain that 00:18:43.079 --> 00:18:46.490 information for the next generations or from the next 00:18:46.490 --> 00:18:50.240 people were gonna be filling those shoes. 00:18:50.240 --> 00:18:52.819 So um the next kind of thing that we want to talk 00:18:52.819 --> 00:18:55.779 about is risk models. Now there are no perfect risk 00:18:55.779 --> 00:18:58.869 models. There's a there's different ways of approaching 00:18:58.869 --> 00:19:02.349 this. Um There's I mentioned before the simple handy 00:19:02.359 --> 00:19:05.859 risk base in uh management program which is shrimp 00:19:06.140 --> 00:19:09.470 There's 3rd Party contractors and or you can develop 00:19:09.480 --> 00:19:14.940 your own risk model internally. Now, the best thing 00:19:14.940 --> 00:19:18.920 to do for any risk model is always verify the results 00:19:18.930 --> 00:19:21.309 You want to go back and look at the results and make 00:19:21.309 --> 00:19:24.400 sure that they make sense and really crossing back 00:19:24.400 --> 00:19:28.220 with your service tax, if you, if you get the people 00:19:28.220 --> 00:19:31.259 and the boots on the ground and you say, hey, um our 00:19:31.259 --> 00:19:34.609 number one ranked ranked risk is excavation damage 00:19:34.609 --> 00:19:38.960 And they look at you like you're like questioning it 00:19:38.970 --> 00:19:42.009 saying, hey, we'll know we've seen a lot more on equipment 00:19:42.099 --> 00:19:45.410 that we have on excavation damage. Then you want to 00:19:45.410 --> 00:19:47.700 go back and see if you, if your risk model there, you're 00:19:47.700 --> 00:19:52.380 feeding the correct of the correct data or if you have 00:19:52.390 --> 00:19:56.569 other issues underlying going mhm. Another thing I 00:19:56.569 --> 00:19:58.990 always that I can't emphasize enough, the shrimp model 00:19:58.990 --> 00:20:02.990 does not do your baseline for you, Make sure that for 00:20:02.990 --> 00:20:05.349 those of y'all are used in the program that you are 00:20:05.349 --> 00:20:10.559 taking that extra step. Um and uh and making sure you're 00:20:10.559 --> 00:20:13.440 establishing your baseline. 00:20:13.440 --> 00:20:17.359 So a lot of people ask how now, how do I document 00:20:17.940 --> 00:20:21.980 what I'm doing now? Um for especially for for each 00:20:21.980 --> 00:20:25.579 step. So one thing that is a really good, it is not 00:20:25.579 --> 00:20:28.180 required by code, but it's a very useful way of documenting 00:20:28.180 --> 00:20:31.579 is doing annual, I like to call annual summer. So annual 00:20:31.579 --> 00:20:35.930 summaries is basically, it can be as complex or as 00:20:35.930 --> 00:20:38.529 simple as you can, it can be bullets. It could be something 00:20:38.529 --> 00:20:41.359 like full and report, but what you really want to do 00:20:41.359 --> 00:20:46.049 is every single year, um kind of create, create a simple 00:20:46.049 --> 00:20:49.359 summary of what you did that previous calendar year 00:20:49.740 --> 00:20:54.670 It's time to do this is uh when you're doing your annual 00:20:54.670 --> 00:20:58.410 reports or immediately after your annual reports. So 00:20:58.410 --> 00:21:01.319 then you could summarize what you're, what you're actually 00:21:02.140 --> 00:21:07.519 So a good example of of annual summaries is that when 00:21:07.519 --> 00:21:10.250 when we've run all the numbers for your annual reports 00:21:10.259 --> 00:21:14.349 you can explain some of the trends because some people 00:21:14.349 --> 00:21:16.480 ask, well, how do I explain the trend was like, well 00:21:16.490 --> 00:21:19.650 during these annual summaries, you can say that. Well 00:21:19.660 --> 00:21:24.349 on our example for the 2000 and 18, 11 call one call 00:21:24.349 --> 00:21:26.930 tickets, why did increase, why did it spike? Well, 00:21:26.930 --> 00:21:29.500 it could be something as simple as a T. And T. Came 00:21:29.500 --> 00:21:33.279 through your town and salt, fiber optic cables and 00:21:33.289 --> 00:21:35.779 that's, that's what happened. And so then you want 00:21:35.779 --> 00:21:38.390 to document that and you can document that during these 00:21:38.390 --> 00:21:40.930 annual summaries. So then you can say, and you're documenting 00:21:40.930 --> 00:21:43.420 saying that, hey, this is the reason why it's like 00:21:43.420 --> 00:21:45.779 this is the reason why we have so many tickets for 00:21:45.779 --> 00:21:49.480 this particular year. Um and you know, it's something 00:21:49.480 --> 00:21:52.700 that you can easily kind of throw together um kind 00:21:52.700 --> 00:21:55.960 of have like a of meeting with all your service text 00:21:55.960 --> 00:21:58.809 as an example during that and kind of discuss, well 00:21:58.809 --> 00:22:00.690 what type of activities have you done? Which have you 00:22:00.690 --> 00:22:04.250 completed? Um and you can, and that's, it's a really 00:22:04.250 --> 00:22:07.039 good way of documents. 00:22:07.039 --> 00:22:11.660 So one thing that I always like to say is that um 00:22:12.640 --> 00:22:15.799 whenever you have your dim program and whenever you're 00:22:15.799 --> 00:22:19.109 putting it all together, if you don't do the steps 00:22:19.119 --> 00:22:21.660 early on every single step as thoroughly and completely 00:22:21.660 --> 00:22:25.589 as you possibly can um your, your, your gym program 00:22:25.589 --> 00:22:27.410 is going to start having shortcomings, it is going 00:22:27.410 --> 00:22:31.519 to fall apart and uh especially the steps early on 00:22:31.529 --> 00:22:35.069 if you don't do steps, if you mess up on step two 00:22:35.079 --> 00:22:37.450 steps 45 and six, you're gonna be, it's gonna be really 00:22:37.450 --> 00:22:39.269 hard. It's gonna be really hard to actually put it 00:22:39.269 --> 00:22:42.410 together. So there's always room for improvement, There's 00:22:42.410 --> 00:22:44.880 always a room of actually going back and looking at 00:22:44.880 --> 00:22:46.549 to make sure I am I doing this step thoroughly and 00:22:46.549 --> 00:22:49.400 completely and you want to be out, you want to be uh 00:22:49.410 --> 00:22:51.690 answering those questions and I was mentioned before 00:22:51.700 --> 00:22:54.059 to kind of help you as a guidance to say, am I 00:22:54.059 --> 00:22:59.039 mean like the intent of this particular, 00:22:59.039 --> 00:23:02.049 So um the next we're going to talk about is a common 00:23:02.049 --> 00:23:07.940 mistakes that we see out in uh 00:23:07.940 --> 00:23:11.730 out in the field for from from the last five years 00:23:11.740 --> 00:23:15.730 roughly. Uh So some of the common violations, The biggest 00:23:15.730 --> 00:23:19.140 one is baseline for each performance measure. So this 00:23:19.140 --> 00:23:21.839 one really deals with is kind of on both sides. Either 00:23:21.849 --> 00:23:25.000 operators are not having establishing what their baseline 00:23:25.000 --> 00:23:29.519 is, lack of procedures, lack of documentation. Um Sometimes 00:23:29.529 --> 00:23:33.380 the baselines are not clearly stated. Um It's not, 00:23:33.390 --> 00:23:35.910 it's not always assumed that the starting a program 00:23:35.910 --> 00:23:38.000 is starting their baseline. It doesn't work that way 00:23:38.000 --> 00:23:40.970 You have to establish, you have to document that you 00:23:40.980 --> 00:23:45.539 did that particular year or a series of years or an 00:23:45.539 --> 00:23:50.250 average of years. Um what's your baseline is for each 00:23:50.250 --> 00:23:52.609 performance measures. So those are five performance 00:23:52.609 --> 00:23:54.730 measures that we talked about before. Each one of those 00:23:54.730 --> 00:23:56.509 are the mandatory performance measures that you have 00:23:56.509 --> 00:24:02.890 to document each one of those um for uh in order to 00:24:02.890 --> 00:24:06.440 meet compliance. So another, another common violation 00:24:06.440 --> 00:24:09.220 that we have is a periodic reviews. We've seen this 00:24:09.220 --> 00:24:11.859 in a couple of different different aspects. One of 00:24:11.859 --> 00:24:14.869 them is just not meeting their required intervals if 00:24:14.869 --> 00:24:19.049 your procedures says that you're going to do a periodic 00:24:19.049 --> 00:24:21.529 review every three years and we are going to hold you 00:24:21.529 --> 00:24:24.230 to it because it's within your procedures, so make 00:24:24.230 --> 00:24:28.029 sure that you are following not only you but also your 00:24:28.029 --> 00:24:31.240 on procedure and just a general lack of documentation 00:24:31.240 --> 00:24:37.240 for for pr um something like the specifically says 00:24:37.240 --> 00:24:42.400 a complete evaluation um and if you're not doing a 00:24:42.400 --> 00:24:44.930 complete evaluation, if you if you're and you're not 00:24:44.930 --> 00:24:47.200 documenting that you're a complete evaluation, that's 00:24:47.200 --> 00:24:49.890 something that that we do look at. Something that we 00:24:49.890 --> 00:24:52.240 do like to encourage you all to document as much as 00:24:52.240 --> 00:24:55.849 you can what you actually look at who looked at it 00:24:56.640 --> 00:25:02.700 etcetera. Um and kind of an overall one would be kind 00:25:02.700 --> 00:25:06.359 of a general lack of documentation for the implementation 00:25:06.359 --> 00:25:09.880 of every single step. So make sure that you are documenting 00:25:09.880 --> 00:25:12.750 every single step as thoroughly and completely as you 00:25:12.750 --> 00:25:15.039 possibly can. Some of the steps are a little bit more 00:25:15.039 --> 00:25:18.299 prescriptive than others, but and you there is ways 00:25:18.299 --> 00:25:20.769 of document everything and one thing that, well that 00:25:20.940 --> 00:25:23.049 that I like to say is some of your procedures are going 00:25:23.049 --> 00:25:25.490 to be your documentation, so you don't have to do like 00:25:25.490 --> 00:25:28.470 so many extra steps and document everything else, sometimes 00:25:28.480 --> 00:25:31.940 it's pretty embedded within your procedure but uh but 00:25:31.940 --> 00:25:34.890 some of them are not like if you're doing if you're 00:25:34.890 --> 00:25:37.609 taking steps above and beyond code, you need to be 00:25:37.609 --> 00:25:39.940 documented every single step, every single step every 00:25:39.940 --> 00:25:43.720 single year, you want to be documenting what you're 00:25:43.720 --> 00:25:45.559 doing and giving yourself credit for what you're doing 00:25:46.140 --> 00:25:49.349 Um Another one that we have to start that I started 00:25:49.349 --> 00:25:53.079 to see an uptick the last couple of years is uh with 00:25:53.079 --> 00:25:55.450 respect to your facility replacement program which 00:25:55.450 --> 00:26:01.480 is required by the texas ministry 8.209. Um We're gonna 00:26:01.480 --> 00:26:03.609 be reviewing, this is a little bit and in detail a 00:26:03.609 --> 00:26:06.089 little bit more, but generalistic lee speaking, we 00:26:06.089 --> 00:26:09.650 have seen that start to uptake in terms of violations 00:26:09.650 --> 00:26:13.339 We have we have seen a lot of Operators or a fair 00:26:13.339 --> 00:26:16.740 bit of operators starting starting to not not specifying 00:26:16.750 --> 00:26:20.559 what the highest risk is and not meeting the eight 00:26:20.940 --> 00:26:26.900 A replacement per year, 5% previously. Um But uh it's 00:26:26.900 --> 00:26:30.599 mostly lack of procedures is what we've seen is that 00:26:30.609 --> 00:26:33.259 in with with respect to the facility replacement program 00:26:33.740 --> 00:26:36.019 Um and then subsequently if you don't have procedures 00:26:36.019 --> 00:26:37.869 and you don't think you're obviously not going, you're 00:26:37.869 --> 00:26:40.299 not doing it, you're not having documentation. But 00:26:40.299 --> 00:26:42.230 that's really kind of one thing that we have seen quite 00:26:42.230 --> 00:26:45.869 a bit is that that you're not really having your either 00:26:45.880 --> 00:26:49.319 your own standalone procedures or as part of your project 00:26:49.319 --> 00:26:53.559 program. Um This is a state or a texas specific code 00:26:53.740 --> 00:26:57.549 So like for example, the shrimp programme does not 00:26:57.559 --> 00:27:00.640 do does not even address the facility placement program 00:27:00.640 --> 00:27:03.650 under TCP two oh nine. So that's kind of something 00:27:03.650 --> 00:27:06.539 to to kind of keep in mind. 00:27:06.539 --> 00:27:09.559 So the next one uh is gonna be we're gonna be talking 00:27:09.559 --> 00:27:13.750 about this facility replacement program. Uh Now the 00:27:13.759 --> 00:27:19.599 one thing that uh 8.29 Very specifically says is that 00:27:19.609 --> 00:27:23.240 your that is a risk based program that is intended 00:27:23.240 --> 00:27:27.900 to work in conjunction with the dem program. So the 00:27:27.900 --> 00:27:30.569 idea was that we didn't want you to like reinvent the 00:27:30.569 --> 00:27:34.089 wheel here. We wanted you to use or take that extra 00:27:34.089 --> 00:27:38.230 step here in texas and say that while while utilizing 00:27:38.230 --> 00:27:40.980 your gent program we're already doing a risk analysis 00:27:40.990 --> 00:27:43.089 there are more than welcome to do another one if you 00:27:43.089 --> 00:27:47.460 really so choose to. But you know, the idea was for 00:27:47.839 --> 00:27:50.180 the facility replacement program is to work with your 00:27:50.180 --> 00:27:53.589 gym program. It was intended to work with for you in 00:27:53.589 --> 00:27:55.960 the state of texas for you to take that extra step 00:27:56.539 --> 00:28:01.609 That really was, was the idea now That said there has 00:28:01.609 --> 00:28:06.519 been a couple of changes uh in particular for the replacement 00:28:06.529 --> 00:28:10.960 percentages effective January 6, 2020. Um it changed 00:28:10.960 --> 00:28:15.480 from a 5% replacement 8% replacement. So kind of keep 00:28:15.480 --> 00:28:19.170 that in mind now this is always in two parts. Um this 00:28:19.170 --> 00:28:23.029 is the The 8% replacement of the facilities posing 00:28:23.029 --> 00:28:25.700 the greatest risk and the second part is identified 00:28:25.700 --> 00:28:30.890 for replacement. So one thing that has come up in the 00:28:30.890 --> 00:28:37.329 past is that your greatest risk may not be uh in conjunction 00:28:37.329 --> 00:28:40.140 with identifying for replacement. So if you have, so 00:28:40.140 --> 00:28:42.680 for example, the biggest one that always comes up is 00:28:42.680 --> 00:28:45.890 an excavation damage of excavation damage is your number 00:28:45.890 --> 00:28:48.930 one ranked risk. We're not expecting you to replace 00:28:48.940 --> 00:28:51.619 to replace. Perfect the pipe, that's where that second 00:28:51.619 --> 00:28:54.359 caveat came in to where identified for replacement 00:28:54.839 --> 00:28:59.369 So uh what we always go back and look and say, okay 00:28:59.369 --> 00:29:01.740 well if you're number one is excavation damage? All 00:29:01.740 --> 00:29:03.880 right, well what's the number two, Number three, Number 00:29:03.880 --> 00:29:06.460 four. And what you were going to be doing doing about 00:29:06.460 --> 00:29:11.250 those uh specific. So, I mean just because it's uh 00:29:11.259 --> 00:29:13.289 it's your number one or your greatest risk for your 00:29:13.289 --> 00:29:16.069 system. You know, we we do give a little bit of leeway 00:29:16.069 --> 00:29:21.750 for them. Um Now the next one is the fact that I 00:29:21.750 --> 00:29:27.730 have to mention is 8.209 part I, which is which is 00:29:27.730 --> 00:29:30.319 a requirement that no later than March 15th of each 00:29:30.319 --> 00:29:34.440 year that you must be submitting to to the, to the 00:29:34.440 --> 00:29:36.609 division, which is the pipeline safety department, 00:29:36.619 --> 00:29:40.180 what you replaced your previous calendar year and what 00:29:40.180 --> 00:29:43.829 you plan to replace that calendar, So kind of what 00:29:43.829 --> 00:29:46.680 you did last year and what you plan to do this year 00:29:46.680 --> 00:29:50.029 type situation um and how and how you do that? Is that 00:29:50.029 --> 00:29:54.450 you you submit that to um safety at RC dot texas dot 00:29:54.450 --> 00:29:58.980 gov. And another thing to mention is that um if steel 00:29:58.980 --> 00:30:01.910 service lines ends up being your number one, your highest 00:30:01.910 --> 00:30:04.460 risk facility, then you do have to do extra steps. 00:30:04.839 --> 00:30:09.940 Um not just outlined here in 209 but uh to uh nine 00:30:09.940 --> 00:30:12.920 I but about 209 in general. So just kind of keep that 00:30:12.920 --> 00:30:18.359 in mind. Uh Now what to expect from an inspection. 00:30:19.140 --> 00:30:23.329 So whenever you get that that fun phone call from from 00:30:23.339 --> 00:30:25.900 from an inspector, they're going to call you and say 00:30:25.900 --> 00:30:28.980 I want to do a distribution integrity management inspection 00:30:28.990 --> 00:30:34.539 with this municipality or with us an operator. Um One 00:30:34.539 --> 00:30:38.029 thing to keep in mind is that we do have a new 00:30:38.029 --> 00:30:42.180 jump form uh and we are updating it periodically. That's 00:30:42.180 --> 00:30:46.150 a combination of both state and federal code. Um And 00:30:46.160 --> 00:30:49.460 and we are including the distribution facility replacement 00:30:49.839 --> 00:30:55.000 So because we do update them periodically, uh please 00:30:55.000 --> 00:30:57.390 ask the inspector Whenever you get that phone call 00:30:57.400 --> 00:30:59.660 please ask them for the latest form to make sure that 00:30:59.660 --> 00:31:02.589 you are up to date. Um It really hasn't changed very 00:31:02.589 --> 00:31:06.150 often, but you know, uh it does it does get updated 00:31:06.150 --> 00:31:08.059 and does get looked at periodically to make sure that 00:31:08.059 --> 00:31:12.160 we're in compliance. So please ask your inspectors 00:31:12.160 --> 00:31:17.279 for uh for the latest for Now. 1 1 of the things 00:31:17.279 --> 00:31:19.849 that you want to come prepared with is a lot of the 00:31:19.849 --> 00:31:27.440 records uh that is ah proving compliance with with 00:31:27.440 --> 00:31:32.210 the debt with jim. Now it's not just the records. It's 00:31:32.210 --> 00:31:35.579 all you also want to come with your debt manual and 00:31:35.579 --> 00:31:39.460 your procedures or any supporting procedures um supporting 00:31:39.460 --> 00:31:43.539 documentation. Uh So you're did manuals is going to 00:31:43.539 --> 00:31:48.779 be maybe uh have separate subsections. You may have 00:31:48.779 --> 00:31:52.539 a separate um manual for your facility replacement 00:31:52.539 --> 00:31:55.710 program. That's perfectly fine. You may have it in 00:31:55.710 --> 00:31:58.049 different areas but make sure you bring them all together 00:31:58.940 --> 00:32:01.279 Supporting documentation is pretty much everything 00:32:01.279 --> 00:32:07.009 like maps, leak records, uh legal reports, lead complaints 00:32:07.019 --> 00:32:09.390 um Your annual summaries if you're electing to use 00:32:09.390 --> 00:32:13.180 those, I mean you want to bring as much supporting 00:32:13.180 --> 00:32:16.559 documentation as you can do in order to in order to 00:32:16.559 --> 00:32:19.440 help the process a little bit better. The other one 00:32:19.450 --> 00:32:23.839 with respect to manuals is sometimes we've seen like 00:32:23.839 --> 00:32:26.640 different procedures and like you say you're o and 00:32:26.640 --> 00:32:29.470 m your operation and maintenance manual in particular 00:32:29.470 --> 00:32:31.359 we see that a lot of you like your lead complaints 00:32:31.359 --> 00:32:37.329 leak leak um management program uh and the preceding 00:32:37.329 --> 00:32:40.539 and subsequent procedures are in sometimes we see them 00:32:40.539 --> 00:32:42.509 in separate manuals. So make sure you bring those as 00:32:42.509 --> 00:32:46.099 well. Uh In particular like we have seen your facility 00:32:46.099 --> 00:32:49.619 of replacement program. Uh We do we don't normally 00:32:49.619 --> 00:32:51.880 see it with your dent program. Sometimes we do sometimes 00:32:51.880 --> 00:32:55.730 you don't but wherever your procedures are or any additional 00:32:55.730 --> 00:32:58.829 manuals. Any additional procedures Please make sure 00:32:58.829 --> 00:33:01.339 that that you have those you're bringing us as well 00:33:01.349 --> 00:33:05.559 Um as well as um any operating personnel for those 00:33:05.559 --> 00:33:09.250 who are actually like filling out some like for example 00:33:09.250 --> 00:33:11.809 your annual reports, those that are actually filling 00:33:11.809 --> 00:33:15.710 out um like some of like your leak reports and complaints 00:33:15.710 --> 00:33:19.170 sometimes. Well I have additional questions um depending 00:33:19.180 --> 00:33:21.869 depending on like throughout the course of inspections 00:33:21.880 --> 00:33:24.589 so please make sure you do that you do come in and 00:33:24.599 --> 00:33:29.400 you look at or you do have the of those um those 00:33:29.400 --> 00:33:33.410 operating personnel and manuals handy. Um Now the other 00:33:33.420 --> 00:33:37.900 the other one is for after after after an inspection 00:33:37.910 --> 00:33:41.430 if you do get an alleged violation that when you are 00:33:41.430 --> 00:33:45.869 responding to them that you are giving um that you 00:33:45.869 --> 00:33:48.980 are sending documentation or evidence of those alleged 00:33:48.980 --> 00:33:51.299 violations and that you are saying that you're sending 00:33:51.299 --> 00:33:55.390 them to uh to austin at the safety on irc dot texas 00:33:55.390 --> 00:34:00.309 dot gov uh that you are reading that uh that letter 00:34:00.309 --> 00:34:03.650 thoroughly and completely in particularly the notes 00:34:03.650 --> 00:34:06.470 and make sure that you are sending documentation that 00:34:06.480 --> 00:34:09.480 you did complete or you did come back into compliance 00:34:09.489 --> 00:34:13.969 So a good example of that one would be if you got 00:34:13.969 --> 00:34:17.150 a procedural violation some something that that your 00:34:17.150 --> 00:34:20.250 procedures are not made in compliance with, that you 00:34:20.250 --> 00:34:23.690 are sending a copy of that particular section or your 00:34:23.690 --> 00:34:26.820 manual to prove that you did change it or that you 00:34:26.820 --> 00:34:29.829 did updated to make them clients. Um And the other 00:34:29.829 --> 00:34:32.440 one is that we that I always like to mention is that 00:34:32.440 --> 00:34:35.380 we do have an open door policy. So if you have any 00:34:35.380 --> 00:34:38.920 questions about violation or alleged violation give 00:34:38.920 --> 00:34:41.420 us a call, we want, we want to make sure that you 00:34:41.420 --> 00:34:44.309 are doing the right thing that you are meeting compliance 00:34:44.309 --> 00:34:47.159 with code. And if you have any questions about about 00:34:47.170 --> 00:34:51.360 any either alleged violation or or even before that 00:34:51.369 --> 00:34:54.599 you know, we do want, we do like to have those open 00:34:54.599 --> 00:34:59.690 lines of communication. So uh the last, the last thing 00:34:59.690 --> 00:35:02.519 that I always like to mention, especially with in preparation 00:35:02.519 --> 00:35:06.269 for for a jump inspection is that uh is it doesn't 00:35:06.269 --> 00:35:08.469 start when you get the phone call, it starts well before 00:35:08.940 --> 00:35:13.489 so you want to be documenting every um like you have 00:35:13.489 --> 00:35:17.380 to think of your program as a live document like you 00:35:17.380 --> 00:35:19.710 want to be documented every step every action every 00:35:19.710 --> 00:35:23.739 year. Um please please, I'd like to encourage them 00:35:23.739 --> 00:35:27.619 the annual summaries or however you all documented 00:35:27.630 --> 00:35:31.360 like you want, you want to keep keep up with what with 00:35:31.360 --> 00:35:34.519 what you're doing because I mean especially when it 00:35:34.519 --> 00:35:37.699 comes to the periodic evaluations once every five years 00:35:37.710 --> 00:35:40.659 if you're not documenting everything every year. I 00:35:40.659 --> 00:35:42.389 mean it is very difficult to remember what you did 00:35:42.389 --> 00:35:47.380 five years ago. So please keep that in mind document 00:35:47.380 --> 00:35:49.789 as much as you can give yourself credit for what you're 00:35:49.789 --> 00:35:58.380 doing and um and just document now on the screen is 00:35:58.380 --> 00:36:01.610 a copy of my contact information. If you have any questions 00:36:01.619 --> 00:36:04.800 comments or social observations. Feel free to give 00:36:04.800 --> 00:36:07.360 me a call. Feel free to send me an email. I'm very 00:36:07.360 --> 00:36:13.239 open about answering any questions, comments uh mean 00:36:13.730 --> 00:36:16.280 curveballs by all means. If you if you have questions 00:36:16.280 --> 00:36:19.539 about how to apply specific code or were to get more 00:36:19.539 --> 00:36:21.849 additional information, feel free to give me a call 00:36:22.829 --> 00:36:28.409 Um That said um does anyone have any questions, comments 00:36:28.409 --> 00:36:32.059 or social observations? And I'm opening in the floor 00:36:39.929 --> 00:36:42.610 don't really see anything in the Q. And A. Okay. Here 00:36:42.610 --> 00:36:49.530 we go. 00:36:49.530 --> 00:36:55.130 All right, well if uh 00:36:55.130 --> 00:36:59.630 oh thank you sir. Matthew. 00:36:59.630 --> 00:37:02.480 All right, well if that's if that's it, I'm pretty 00:37:02.480 --> 00:37:06.360 much uh that in my presentation I'll hang out for a 00:37:06.360 --> 00:37:09.429 little bit if anyone wants to send anything to the 00:37:09.429 --> 00:37:14.019 Q. And A. But that's pretty much all I have another 00:37:14.019 --> 00:37:16.699 one is the last thing that I always like to mention 00:37:16.710 --> 00:37:20.780 or that I have to mention is that please complete a 00:37:20.789 --> 00:37:25.530 evaluation. It is available for my particular video 00:37:25.530 --> 00:37:28.050 if you liked it. If you wanted to kind of leave comments 00:37:28.429 --> 00:37:31.409 please fill out a survey. This video is going to be 00:37:31.409 --> 00:37:34.610 archived and it's going to be available on our website 00:37:34.619 --> 00:37:38.489 So if you have it, if I would like to encourage you 00:37:38.489 --> 00:37:40.289 all to actually go and fill out a survey. If you guys 00:37:40.289 --> 00:37:43.809 can please please please uh makes my life a little 00:37:43.809 --> 00:37:50.260 bit easier. Um But other than that I think I will end 00:37:50.260 --> 00:37:54.230 it here and if anyone has any other 00:37:54.230 --> 00:38:23.320 questions I'll be around. 00:38:23.320 --> 00:38:24.920 There is a question available sir if you want to go 00:38:24.920 --> 00:38:30.739 ahead and answer that. Okay, so the question is if 00:38:30.739 --> 00:38:35.539 an operator executes a risk assessment using subcategories 00:38:36.219 --> 00:38:40.260 um and a complex algorithm, how deep into the results 00:38:40.329 --> 00:38:44.460 of the inspectors typically dig? Um Well that depends 00:38:44.469 --> 00:38:49.380 uh that depends on the algorithm if it's as complex 00:38:49.380 --> 00:38:54.039 as you were saying um and then they can go pretty deep 00:38:54.050 --> 00:38:59.429 uh the vast majority of time they look at um where's 00:38:59.429 --> 00:39:03.760 your sources of information? Like what, what is feeding 00:39:03.760 --> 00:39:07.280 into the algorithm type situation um and then from 00:39:07.280 --> 00:39:11.789 the results standpoint um I mean any algorithm and 00:39:11.789 --> 00:39:18.019 any risk model is going to be giving uh like is going 00:39:18.019 --> 00:39:20.809 to give an output. So depending on how, depending on 00:39:20.809 --> 00:39:24.789 how output or what type of results that you're actually 00:39:24.789 --> 00:39:32.320 getting. Um It kind of depends on um 00:39:32.320 --> 00:39:36.030 what what are you using that information for. So the 00:39:36.039 --> 00:39:39.530 model, the risk models are intended as a as a guidance 00:39:39.530 --> 00:39:42.719 as a tool for you to be making integrity management 00:39:42.719 --> 00:39:48.239 decisions, especially on that next step which is um 00:39:49.119 --> 00:39:57.559 evaluating or measures to address risk. So uh it honestly 00:39:57.559 --> 00:40:00.030 depends on the on the inspector but the vast majority 00:40:00.030 --> 00:40:03.000 of the time they will be looking at to say okay, what 00:40:03.000 --> 00:40:05.730 what are the results and how and how are using them 00:40:05.739 --> 00:40:09.679 Um We are all restricted by two things. Time and money 00:40:09.690 --> 00:40:14.300 So we all have, we only have 365 days at a year 00:40:14.300 --> 00:40:18.630 and we only have a limited budget to utilize our resources 00:40:18.639 --> 00:40:23.349 So depending on the results of this out of your risk 00:40:23.349 --> 00:40:26.400 algorithm, your risk assessment, they're saying that 00:40:26.400 --> 00:40:34.320 okay, well um how how how are you utilizing the information 00:40:34.320 --> 00:40:37.530 to make a good informed to demand of the decision? 00:40:40.010 --> 00:41:05.510 Okay, let's see. Mhm. 00:41:05.510 --> 00:41:09.929 Oh no, no, no I encourage the discussion so not at 00:41:09.929 --> 00:41:22.210 all. Um 00:41:22.210 --> 00:41:25.000 Okay, so I have heard that before that that they think 00:41:25.000 --> 00:41:30.030 it's too much data crunching is too much impact. So 00:41:30.039 --> 00:41:33.070 assumptions are really hard because then now now you're 00:41:33.070 --> 00:41:40.059 making a decision for the entire system um Yeah, I 00:41:40.070 --> 00:41:43.610 I haven't really seen it negatively impact the operator 00:41:43.610 --> 00:41:46.429 that much. I mean even when you're looking at like 00:41:46.429 --> 00:41:51.130 say the shrimp program they asked well over 100 questions 00:41:51.139 --> 00:41:54.639 I mean it really goes into very, very fine granular 00:41:54.639 --> 00:41:59.780 detail, so I mean depending on depending on the operator 00:41:59.789 --> 00:42:03.119 how big your your system is and how you define this 00:42:03.119 --> 00:42:06.110 system a lot of that really. There's a lot of depends 00:42:06.110 --> 00:42:10.610 in there. Uh So I mean the more complex of the risk 00:42:10.610 --> 00:42:14.699 model. Generalistic lee is the better. Um but it also 00:42:14.699 --> 00:42:16.920 comes with starting caveats, what like kind of like 00:42:16.920 --> 00:42:22.340 what I was saying, what, what are your um what are 00:42:22.340 --> 00:42:26.300 your input? I mean well what type of, where the information 00:42:26.300 --> 00:42:29.750 coming from? Is it solely leak based are you like, 00:42:29.750 --> 00:42:32.280 what type of weight factors are you putting in into 00:42:32.280 --> 00:42:35.280 the risk model? Um and then what type of assumptions 00:42:35.280 --> 00:42:37.599 are you are doing their of like in terms of like the 00:42:37.599 --> 00:42:41.000 values of those weight factors, I mean there's there's 00:42:41.000 --> 00:42:44.320 kind of like it can go a lot of different ways so 00:42:45.599 --> 00:42:51.260 um and every every system is uniquely different uh 00:42:51.269 --> 00:42:53.659 or it can be uniquely different. There's a lot of parallels 00:42:53.659 --> 00:42:56.929 but they can be uniquely different. So it kind of like 00:42:56.940 --> 00:42:59.019 especially when it comes to risk models is the reason 00:42:59.019 --> 00:43:01.909 why I one of the first things I said is no risk 00:43:01.909 --> 00:43:06.429 models. Perfect. So you want to utilize those results 00:43:06.429 --> 00:43:09.400 validate them with your text in the field. You want 00:43:09.400 --> 00:43:12.469 to go back and make sure that the results that you 00:43:12.469 --> 00:43:15.949 are getting makes sense for the type of leaks that 00:43:15.949 --> 00:43:18.719 you're having your number of leaks every having or 00:43:18.719 --> 00:43:21.489 if you're not have any leaks at all. I mean I have 00:43:21.489 --> 00:43:23.639 seen a lot of operators out there, especially small 00:43:23.650 --> 00:43:26.730 small met operators that they have very limited leaks 00:43:26.730 --> 00:43:31.440 to begin with. So like even just one or two leaks really 00:43:31.440 --> 00:43:35.139 drastically changes the model for them versus major 00:43:35.139 --> 00:43:38.679 operators. I mean it's like a drop in the bucket because 00:43:38.679 --> 00:43:41.139 you have leaks all over the place because of the sheer 00:43:41.150 --> 00:43:46.469 size of their operation. So it really is really, really 00:43:46.469 --> 00:43:49.889 is hard. Whenever you're looking at a certain like 00:43:49.900 --> 00:43:53.250 weight values and wait functions, it will be very different 00:43:53.260 --> 00:43:56.460 from a major operator versus smaller. And even with 00:43:56.460 --> 00:44:01.590 major operators, sometimes you see them uh going back 00:44:01.599 --> 00:44:06.789 and uh subdividing their systems. Uh So that's kind 00:44:06.789 --> 00:44:09.300 of all these different factories and stuff that you 00:44:09.300 --> 00:44:14.389 that you want to look at. 00:44:14.389 --> 00:44:33.090 Tanya. Welcome. 00:44:33.090 --> 00:44:55.889 Mhm. 00:44:55.889 --> 00:45:02.289 Any other questions comments. 00:45:02.289 --> 00:45:04.719 Hopefully my presentation wasn't. I didn't go too fast 00:45:20.590 --> 00:45:45.489 Yeah. 00:45:45.489 --> 00:45:47.969 Well, that looks like all the questions you're going 00:45:47.969 --> 00:45:53.889 to get. All right, okay. 00:45:53.889 --> 00:45:57.219 Okay. Y'All have a good one.