In This Issue

OPS Releases Gas Distribution IMP Report

A collaborative effort of regulatory agencies, gas distribution operators, and public stakeholders have published “Integrity Management for Gas Distribution – Report of Phase I Investigations.” Four multi-stakeholder work/study groups were established to collect and analyze available information and to reach findings and conclusions to inform future work by the PHMSA relative to implementing integrity management principles for gas distribution pipelines. The groups have concluded that current pipeline safety regulations (49 CFR Part 192) do not now convey the concept of a risk-based distribution integrity management process and that it would be appropriate to modify the regulations to do so.

The groups found that the most useful option for implementing distribution integrity management requirements is a high-level, flexible federal regulation, in conjunction with implementation guidance, a nationwide education program expected to be conducted as part of implementing 3-digit dialing for One-Call programs, and continuing research and development.

Differences between gas distribution pipeline operators and the pipeline systems they operate make it impractical to apply the integrity management requirements for transmission pipelines to distribution. The significant diversity among gas distribution pipeline operators also makes it impractical to establish prescriptive requirements that would be appropriate for all circumstances. Instead, the groups concluded that it would be appropriate to require that all distribution pipeline operators, regardless of size, implement an integrity management program including seven key elements, namely that each operator:

  1. Develop and implement a written integrity management plan.
  2. Know its infrastructure.
  3. Identify threats, both existing and of potential future importance.
  4. Assess and prioritize risks.
  5. Identify and implement appropriate measures to mitigate risks.
  6. Measure performance, monitor results, and evaluate the effectiveness of its programs, making changes where needed.
  7. Periodically report a limited set of performance measures to its regulator.

For a copy of the report or to obtain more information about RCP’s pipeline integrity management services, please contact Jessica Roger at RCP.