The
following Distribution Integrity Management Frequently Asked Questions were
updated or added on March 10, 2011.
C.3.8 What do operators need to have implemented by August 2, 2011?
By August 2, 2011, operators of gas distribution systems (other than a master
meter or small LPG operator) must have developed and implemented an integrity
management program that includes a written integrity management plan. The plan
must include the operator’s procedures used to develop the seven elements
listed in § 192.1007(a)-(g) At a minimum, an operator must have taken the
following actions:
- Developed and demonstrated an understanding of their system;
- Identified and considered threats to each gas distribution facility
- Completed a risk evaluation and ranking of their distribution system;
- Developed criteria for deciding when risks require measures to reduce them;
- Determined the measures to reduce risk;
- Begun implementing the measures to reduce risk or have a plan to implement measures to reduce risk which includes an implementation schedule;
- Assessed the effectiveness of their leak management program and taken steps, if necessary, to correct deficiencies;
- Established a baseline measurement for each performance measure required by 192.1007(e)(1)(i)-(v);
- Developed performance measures to evaluate the effectiveness of measures to reduce risk, have a plan to collect the performance measure data, and begun collecting data to establish a baseline measurement;
- Determined the appropriate period for conducting DIMP program evaluations;
- Reported performance measures required by 192.1007(g) for calendar year 2010;
- Collected data as needed for mechanical fitting failures resulting in hazardous leaks beginning January 1, 2011; and
- Identified records requiring retention and have maintained them.
C.4.a.5 What comprises “reasonably available” information?
PHMSA does not intend that operators expend excessive effort, review every
record available in their archives, or explore every nuance about their
pipelines. At the same time, PHMSA expects that operators will devote
sufficient effort to develop as thorough an understanding of their pipelines as
they can while using reasonable effort.
The availability of records will vary among operators. Some operators may
retain records for many years and others only for the length of time required
by Part 192. Some data is stored electronically and some is paper based.
Additionally, some records are stored on-site and other records may be stored
off-site, such as at regional offices or long term storage facilities. Any
record which the operator can access is reasonably available. All records
required by Parts 191 and 192 are reasonably available. Operators need to
review all records that are relevant to the current condition of the pipe or
have a significant impact on the integrity of the pipe. For example, a steel
pipe may have been brought under adequate cathodic protection five years ago
but was not under cathodic protection in prior years. Any records showing that
the pipe was not under cathodic protection, is relevant to the current
condition of the pipe.
Operators must identify additional information that is needed to fill gaps due
to missing, inaccurate, or incomplete records and develop a plan to collect it.
They may collect this information through their normal activities including
those that go beyond those activities specified in Part 192. For example,
missing facility location, material and condition data can be gained when the
pipe is located and/or exposed.
Operators could involve maintenance personnel in their information collection
activities, surveying them about unusual circumstances they have encountered in
their activities and/or asking them to review resulting system descriptions and
identify any information they believe is useful that is not already included.
C.4.a.6 Must an operator’s plan include the sources used to demonstrate an
understanding of its gas distribution system?
An operator needs to be able to demonstrate to regulators that they have an
understanding of their gas distribution system developed using sources of
information that are “reasonably available”. The plan should identify the
information sources. Examples of sources that are reasonably available include
documents, records, field notes, maps, historical procedures and design
standards, bill of materials, procurement records and specifications, and
information obtained from subject matter experts. These sources are used to
identify the characteristics of the pipeline’s design, operations and
environmental factors that are necessary to assess the applicable threats and
risks to the distribution system. Operators also need to consider information
gained from past design, operations, and maintenance. In order to verify that
an operator has met this requirement, the inspector may ask the operator for
information about the sources such as: the name of the documents, the time
period covered by the documents, the document’s location and format (e.g. electronic,
paper, or subject matter expert interview, etc.), the forms used to collect
data, the fields on the forms, the instructions used to complete the forms, and
a history of how this information collection changed over time.
C.4.b.3 The DIMP requirements include knowing the condition of facilities
that are at risk for potential damage from external sources. Cross bores of gas
lines in sewers have been reported at 2-3 per mile in high risk areas –
predominately where trenchless installation methods were used for gas line
installs and where sewers and gas lines are in the proximity of each other.
Does the potential for cross bore of sewers resulting in gas lines intersecting
with sewers need to be determined?
Yes, the threat of excavation damage includes consideration of potential or
existing cross bore of sewers which have resulted in gas lines intersecting
with sewers. Pursuant to § 192.1007(a)(2), the operator must consider
information gained from past design, operations, and maintenance. If operators
used trenchless technologies without taking measures to locate sewer laterals
and other unmarked facilities during construction, there may be a risk that
their facilities were installed through the foreign facility. If this
excavation damage threat applies to the operator, they must evaluate its risk
to their system. Depending on the results of the risk evaluation, they may need
to identify and implement measures to reduce this risk to existing and future
facilities.
C.5.4 Since there is a new form for mechanical fitting failures which result
in a hazardous leak, do these failures still need to be reported under Part C
of the Annual Report?
Yes, operators need to include all mechanical fitting failures which result in
hazardous leaks eliminated or repaired as part of the total leaks reported on
the Annual Report in Part C – TOTAL LEAKS AND HAZARDOUS LEAKS
ELIMINATED/REPAIRED DURING YEAR. Additionally, they must report detailed
information about each mechanical fitting failure which results in a hazardous
leak on a separate Gas Distribution Mechanical Fitting Failure Form (PHMSA
F–7100.1–2).
PHMSA created the new Mechanical Fitting Failure Report form [PHMSA F 7100.1-2]
to address the new annual reporting requirement established by DIMP for
hazardous leaks on mechanical fittings. Operators may submit data at anytime
and at any frequency throughout the year (preferred), or they may submit all
mechanical fitting failure reports in one submission. Regardless of the method
they select, the reports must be submitted by March 15, 2012 for failures which
occurred in calendar year 2011. If an operator does not experience any
mechanical fitting failure which results in hazardous leaks, they do not need
to submit a Mechanical Fitting Failure Report form. The online system for the
new Mechanical Fitting Failure Report form [PHMSA F 7100.1-2] is now in
operation.
NOTE: Online submission via PHMSA Portal is required unless an alternative
reporting method is granted by PHMSA. More information is available at PHMSA’s,
Office of Pipeline Safety web site, Pipeline Safety Community, located at http://www.phmsa.dot.gov/pipeline and click
the “Online Data Entry” hyperlink listed in the first column.
C.8.3 What do master meter and small LPG operators need to have implemented
by August 2, 2011?
By August 2, 2011, master meter operators and small LPG operators must have
developed and implemented a written integrity management program that includes
a written integrity management plan. The plan must include the operator’s
procedures used to develop the elements listed in §192.1015(b)-(c). At a
minimum, these operators must have taken the following actions:
- Developed and demonstrated an understanding of their system;
- Identified and considered threats to each gas distribution facility;
- Completed a relative risk ranking of each identified threat to the distribution system;
- Developed criteria for deciding when risks require measures to reduce them;
- Determined the measures to reduce risk;
- Begun implementing the measures to reduce risk or have a plan to implement measures to reduce risk which includes an implementation schedule;
- Are monitoring the number of leaks eliminated or repaired on its pipeline and their causes.
- Determined the appropriate period for conducting DIMP program evaluations; and
- Identified records requiring retention and have maintained them.