How will small operators, with limited staff, be able to implement the requirements for risk analysis and selection of risk control measures?
The level of analysis required and risk control measures to be implemented are related to the complexity of a distribution pipeline system and the variability across a system in the threats it faces. Operators with small staffs typically operate smaller, simpler systems, so that the effort required to conduct risk analysis and to select risk control measures should be less than that required of operators of more-complex systems. The Gas Piping Technology Committee (GPTC) DIMP guidelines will provide guidance on relatively-simple approaches to risk analysis. The American Public Gas Association (APGA) Security and Integrity Foundation, with partial funding from PHMSA, is also developing the Simple, Handy, Risk-Based, Integrity Management Plan (SHRIMP), a computer-based program that is intended to assist small operators in meeting the analytical requirements of the proposed rule. SHRIMP is intended to be similar to Turbo-tax, providing for input of important facts about a pipeline system
