PHMSA has issued a Notice of Proposed Rulemaking (NOPR) that will require operators of gas distribution pipelines to develop and implement integrity management programs. PHMSA is requesting comments be submitted by September 23, 2008. As proposed, a gas distribution pipeline operator will have 18 months to develop and implement a written integrity management program once the final rule is published. Within Part 192, the NOPR creates a new Subpart P – Gas Distribution Pipeline Integrity Management and deletes §192.383 Excess Flow Valve Customer Notification. Some highlights of the NOPR are listed below:
- Required elements within a DIMP
- Knowledge of gas distribution system – utilization of historical deign and operational data as available and implement processes for capturing this data going forward.
- Identification of threats – corrosion, natural forces, excavation damage, other outside force damage, material/weld failure, equipment malfunction, operations, and other as appropriate
- Evaluate and prioritize risk – allows for threat evaluation of regions within the distribution system that have common characteristics across multiple mains, service lines, etc. carrying similar risks and actions necessary to reduce risks within the same region.
- Identify and implement measures to address risks – implementation of leak management and enhanced damage prevention programs as well as evaluation of human error factors related to inappropriate operations.
- Measure performance, monitor results, and evaluate effectiveness – establish a baseline and measure performance improvements against this in terms of leak mitigation, excavation damage reduction, installation of excess flow valves (EFV), and others as appropriate.
- Periodic evaluation and improvement – establishes a maximum 5 year interval in which gas distribution operators must reevaluate its DIMP. The NOPR also requires operators to continually re-evaluate threats and risks and periodically evaluate human contributions to risk.
- Reporting results – lists four measurements to be included on the operator’s annual report (number of hazardous leaks eliminated/repaired and their cause, number of excavation damages, number of one-call tickets, and number of EFV’s installed).
- Requires gas distribution pipeline operators to report all material failures of plastic pipe within 90 days to PHMSA and appropriate state agency with jurisdiction.
- Provides circumstances when EFV’s are required for new or replaced service lines.
- Allows gas distribution operators to submit requests to PHMSA or the appropriate state agency for extending the frequency of inspections and tests required by Part 192 (e.g. leak survey, corrosion inspection, etc.) based upon engineering analysis and DIMP risk assessments.
- Allows operators of master meter or LPG systems to implement simplified DIMP based upon the simplicity of these types of systems.
For a copy of the NOPR or for information on how RCP can support the development activities of a DIMP, please contact Jessica Roger.