PHMSA Updates DIMP FAQ’s August 2, 2010

PHMSA has posted Frequently Asked Questions for the recently finalized Distribution Integrity Management Program regulation. We have inserted a few noteworthy FAQ’s below. To view the entire list of FAQ’s, click here.

A.8 The regulation exempts the installation of EFVs on services which do not operate at a pressure of 10 psig or greater throughout the year. Can you give examples of types of documentation that would be acceptable in demonstrating this issue?
Two possible methods to demonstrate that services operate at a pressure less than 10 PSIG include; (1) distribution system design documents, validated with actual pressure readings, which show that the main and therefore the associated services are designed to operate below 10 PSIG, or (2) actual pressure recordings or readings on all feeds which are upstream of the service(s) which are less than 10 psig.

B.2.2 Will operators be compared against other operators or national leak or safety data?
PHMSA recognizes that operators need to develop a DIMP plan appropriate for the applicable threats, the operating characteristics of their specific distribution delivery system, and the customers that they serve. PHMSA and State partners intend to focus on each individual operator’s performance trends.

C.3.7 Are operators required to include “farm taps” in their distribution integrity management plan?
In the past, distribution, gathering, and transmission operators connected landowners directly to transmission and gathering pipelines often in exchange for the right to install the pipeline across a landowner’s property. This connection to the gas pipeline is commonly referred to as a “farm tap”. Although new farm taps are not installed nearly as frequently as they were in the past, “farm taps” are very common. The vast majority of “farm taps” meet the definition of a distribution line given that they do not meet the criteria to be classified as a gathering line or a transmission line.

The “farm tap” is pipeline upstream of the outlet of the customer meter or connection to the customer meter, whichever is further downstream, and is responsibility of the operator. The pipeline downstream of this point is the responsibility of the customer. Some States require the operator to maintain certain portions of customer owned pipeline. The pipeline maintained by the operator must be in compliance with 49 Part 192.

Operators of distribution, gathering, and transmission lines with “farm taps” must have a distribution integrity management program meeting the requirements of Subpart P for this distribution pipeline. The DIMP plan is not required to include the customer-owned pipeline (unless required otherwise by State law). The operator having responsibility for operations and maintenance activities for the facility is responsible for developing and implementing the DIMP plan.

C.4.c.2 From which date are operators required to collect data for their Plan?
Operators should use the information they already have and start keeping additional data to develop their plan (e.g., assess the threats) as soon as possible. They need to assemble and evaluate enough data to be able to evaluate the risk. Useful and usable historical data is needed to identify threats and trends.

C.4.g.5 Are multiple tickets for a single job counted as single excavation ticket?
Some state laws require excavators to call in additional requests for on-going jobs prior to the life of the first excavation request expiring. In reporting data these additional requests for excavation projects of extended duration may be counted since there is excavation work associated with those requests. However, operators do not need to change the criteria for counting excavation tickets for the purpose of reporting performance measures. If they currently count multiple tickets for a single job, they may continue that practice. The definition of “ticket” should remain consistent with State law and one-call center definition.

C.5.5 Must operators report to PHMSA mechanical fitting failures that occurred historically (i.e., before a final DIMP rule became effective)?
Currently the DIMP rule states that operators need to collect data about mechanical fitting failures that result in hazardous leaks starting January 1, 2010 but PHMSA published a Federal Register notice on June 28, 2010 to inform operators that the portion of the Annual Report relative to mechanical fitting failures will be delayed by one year and will take effect starting with the 2011 calendar year. PHMSA is developing a final rule to revise the dates in the regulation.

C.7.2 What will PHMSA (or States) require for proposals for alternate inspection intervals?
Proposals must be submitted to each applicable oversight agency (usually the State). Each State will implement this provision under the State’s procedures. State authorities and regulatory structures differ. Requirements for consideration of an alternative interval may differ among State regulatory authorities. The regulatory authority will be responsible for reviewing each proposal, determining safe intervals based on the information in the operator’s proposal, and approving or rejecting the proposal.

Proposed alternative inspection intervals must demonstrate an equal or improved overall level of safety including the effect of the reduced frequency of periodic inspections. A quantitative estimate of risk is not required. PHMSA is developing criteria for evaluating an operator’s alternative interval proposal in the states where PHMSA exercises enforcement authority over distribution pipelines.