Summary of the Proposed Distribution Integrity Management Programs (DIMP) Rule On June 25 the Pipeline And Hazardous Materials Safety Administration (PHMSA) proposed new regulations requiring distribution operators to develop and follow a written Distribution Integrity Management Programs (DIMP) program. PHMSA is seeking public comments up until September 23 after which it will consider the comments an issue a final rule. APGA is already drafting comments on the proposal. PHMSA is proposing to allow operators 18 months after it published its final rule to develop and implement a DIMP program. Considering it typically takes 6-9 months from the date a rule is proposed until it is issued in final form, that means operators will have two years or more before the requirement to have a written DIMP program takes effect. While it is likely the final rule will be somewhat different than the proposed rule, the basic structure will not change. The following is a summary of the proposed rule. Federal pipeline safety regulations will include a new Subpart P--Gas Distribution Pipeline Integrity Management (IM). The required integrity management (IM) program elements are: 1. An operator must demonstrate an understanding of the gas distribution system, including the characteristics of the system and the environmental factors that are necessary to assess the applicable threats and risks to the gas distribution system. The operator must also identify additional information needed and provide a plan for gaining that information over time through normal activities. 2. The operator must consider the following categories of threats to each gas distribution pipeline: a. corrosion, b. natural forces, c. excavation damage, d. other outside force damage, e. material or weld failure, f. equipment malfunction, g. inappropriate operation, and h. any other concerns that could threaten the integrity of the pipeline. An operator must consider incident and leak history, corrosion control records, continuing surveillance records, patrolling records, maintenance history, and “one call'' and excavation damage experience to identify existing and potential threats PHMSA’s proposal deviates from the recommendations of the Phase 1 Report in considering the threat of inappropriate operation (e.g. operator error). The proposed rule would require the operator to address this threat in its DIMP program even if the threat assessment indicates a minimal risk. Since all the studies of distribution incidents cited by PHMSA in the preamble to the rule
found that inappropriate operations was not a significant threat on distribution systems, APGA intends to question why PHMSA proposed to emphasize this threat over the others. 3. An operator must determine the relative probability of each threat and estimate and prioritize the risks posed to the pipeline system 4. The operator must determine and implement measures designed to reduce the risks from failure of its gas distribution pipeline system. At minimum this requires implementing an effective leak management program and enhancing the operator's damage prevention program. APGA presumes PHMSA intends only to require operators to implement risk reduction for those threats found to be significant, but that is not evident in either the rule or the preamble. APGA will seek clarification. The proposal requires than an operator's written IM program contain a separate section with a heading “Assuring Individual Performance” in which an operator must list risk management measures to evaluate and manage the contribution of human error and intervention to risk and implement measures appropriate to address the risk. In addition, this section of the written IM program must consider existing programs the operator has implemented for damage prevention, public awareness, operator qualification and drug and alcohol testing. Once again APGA questions why this single threat, found to be a lesser cause of incidents in the studies cited by PHMSA, merits such special treatment in operator’s IM plans. 5. Operators must develop and monitor performance measures from an established baseline to evaluate the effectiveness of its IM program. An operator must consider the results of its performance monitoring in periodically re-evaluating the threats and risks. Operators must, at minimum, measure the: a. Number of hazardous leaks either eliminated or repaired, categorized by cause; b. Number of excavation damages (Damage means any impact or exposure resulting in the repair or replacement of an underground facility, related appurtenance, or materials supporting the pipeline); c. Number of excavation tickets (receipt of information by the underground facility operator from the notification center); d. Number of EFVs installed; e. Total number of leaks either eliminated or repaired, categorized by cause; f. Number of hazardous leaks either eliminated or repaired, categorized by material; and g. Any additional measures to evaluate the effectiveness of the operator's program in controlling each identified threat.
The first four measure must be reported to PHMSA measures to the State pipeline safety authority in the State where the gas distribution pipeline is located as part of the distribution annual report.
6. An operator must continually re-evaluate threats and risks on its entire system and consider the relevance of threats in one location to other areas. In addition, each operator must periodically evaluate the effectiveness of its program for assuring individual performance to reassess the contribution of human error to risk and to identify opportunities to intervene to reduce further the human contribution to risk. An operator must conduct a complete program re-evaluation at least every five years. PHMSA also proposed that each operator report information on each material failure (e.g. other than excavation damage) of plastic pipe, fittings, couplings, valves and joints no later than 90 days after failure. The report must include location of the failure in the system, nominal pipe size, material type, nature of failure including any contribution of local pipeline environment, pipe manufacturer, lot number and date of manufacture, and other information that can be found in markings on the failed pipe. Operators must also report this information to the State pipeline safety authority in the State where the gas distribution pipeline is located. This is another area where PHMSA has gone beyond the recommendations of its industry government advisory group. PHMSA also proposes to require operators to install excess flow valves on new and replaced single residential service that operate year around at or above 10 psig. Exceptions are provided if EFVs are not available, if it is known there are contaminants in the system that would cause the EFV to fail or if it is known there are liquids in the system. PHMSA proposes to repeal the EFV customer notification rule. PHMSA is proposing that operators maintain forever records used in developing the IM plan, including construction, maintenance and inspection records considered during the threat assessment process. Records of performance measures would be retained for 10 years. Operators may request approval from PHMSA or their State agency to reduce the frequency of periodic inspections and tests required by current pipeline safety rules by providing engineering analysis and risk assessment demonstrating that the reduced frequency will not significantly increase risk. PHMSA, or the applicable State oversight agency, may accept the proposal, with or without conditions and limitations, on a showing that the adjusted interval provides a satisfactory level of pipeline safety. PHMSA is proposing a limited program for LPG piping and master meter systems. The limited program will require: 1. The operator must demonstrate knowledge of the system's infrastructure, which, to the extent known, should include the approximate location and material of its
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distribution system. The operator must identify additional information needed and provide a plan for gaining knowledge over time through normal activities. The operator must consider, at minimum, the following categories of threats (existing and potential): corrosion, natural forces, excavation damage, other outside force damage, material or weld failure, equipment malfunction and inappropriate operation. The operator must determine and implement measures designed to reduce the risks from failure of its pipeline system. The operator must develop and monitor performance measures on the number of leaks eliminated or repaired on its pipeline system and their causes, and The operator must re-evaluate its entire program at least every five years. The operator must consider the results of the performance monitoring in these evaluations. The operator must maintain, for the useful life of the pipeline, the following records: a. A written IM program in accordance with this section; b. Documents supporting threat identification; and c. Documents showing the location and material of all piping and appurtenances that are installed after the effective date of the operator's IM program and, to the extent known, the location and material of all pipe and appurtenances that were existing on the effective date of the operator's program.
PHMSA is considering extending this limited program to small utilities that: 1. Operate at a single pressure, 2. Consist of nothing else but pipe, valves, meters and service regulators, 3. The physical environment (i.e., potential for corrosion) is similar throughout the entire system; 4. Most of the system was installed at one time, consisting of one material. Additions may have been made later of another material, but those additions are limited and their location is known; and 5. The system location allows the operator to exercise control over most third-party excavation. APGA supports providing a simpler program for very small utilities, but questions some of the restrictions in the definition listed above. The APGA Security and Integrity Foundation (SIF) is developing a model IM plan that will meet the requirements of the final DIMP rule. The model plan will be available for review about the same time PHMSA issues a final rule, but no later than 6 months after the date of the final rule.