PHMSA updates Distribution Integrity Management FAQ’s

PHMSA has updated the Gas Distribution Integrity Management FAQ’s. We have included a few of the more interesting FAQ’s, but you can see all of them by clicking here.

B.4.3 Will my plan be in compliance if I use SHRIMP?
The American Public Gas Association’s (APGA) Security and Integrity Foundation (SIF) developed the Simple Handy Risk based Integrity Management Plan (SHRIMP) to assist small operators in creating their written DIMP plan. Using SHRIMP does not necessarily mean that an operator will be in compliance with DIMP requirements. SHRIMP contains generic procedures. An operator’s plan needs to reflect their own procedures, information sources, and practices. The APGA SIF is identifying areas where a SHRIMP user may need to enhance or modify the plan generated by this application to be in compliance with the pipeline safety regulations. Refer to APGA SIF website for the latest information.

C.4.b.5 We used leak causes which we have experienced in the past to identify threats. For example, washouts in our system have not caused leaks in the past so washouts were not identified as a threat. Should washouts be classified as a potential threat due to the possibility of coating damage?
Yes, since the operator experiences washouts, they need to include this specific threat in their risk evaluation. The DIMP rule requires operators to consider both actual and potential threats. Even though washouts have not caused leaks in the past, the fact that pipe is located in areas subject to washouts indicates the potential for leaks due to washouts. The potential for damage (or likelihood of failure) from washout is different for different types of materials. Unsupported or washed out cast iron is much more susceptible to failure than unsupported steel or plastic. The level of risk would also be influenced by the amount of force and the frequency of the force the pipe may experience due to washouts. The measure to reduce risk from washout may require pipe to be buried deep enough to maintain the depth of cover prescribed in Section 192.327 Cover.

C.4.d.11 How can an operator demonstrate that their leak management program is effective?
Operators need to evaluate the effectiveness of their leak management program through a self-audit program. The basic elements of a leak management program are:

1. Locate the leaks in the distribution system – (your plan needs to describe your leakage detection procedures)
2. Evaluate the actual or potential hazards associated with these leaks (your plan needs to describe your leak classification criteria)
3. Act appropriately to mitigate these hazards (your plan needs to describe your leak repair or monitoring schedule)
4. Keep records (of leak surveys, leaks, and self-audit data)
5. Self-assess to determine if additional actions are necessary to keep people and property safe (The purpose of a periodic self-assessment is to determine if the leak management program is effective and, if necessary, to identify changes necessary to ensure that it is effective. Your plan needs to include how you perform your self assessment and the results of the self-assessment.)

An operator must either include the leak management program procedures in its DIMP plan or reference the procedures in your O&M.

C.4.f.2 What constitutes a periodic evaluation?
The operator’s procedure needs to describe the actions the operator will take during the program evaluation. It should include the following actions:

• Description of the frequency of review based on the complexity of the system and changes in factors affecting the risk of failure, not to exceed 5 years
• Verification of general information (e.g. contact information, form names, action schedules, etc.)
• Incorporation of new system information
• Re-evaluation of threats and risk
• Review of the frequency of the measures to reduce risk, where applicable
• Review of the effectiveness of the measures to reduce risk. This includes, at minimum, reviewing the results of the performance measure(s) for each measure taken to reduce risk.
• Review of the measures implemented to reduce risk and refine/improve as needed (i.e. add new, modify existing, or eliminate if no longer needed)
• Review of performance measures, their effectiveness, and if they are not still appropriate, refine/improve

C.5.3 Should both steel and plastic mechanical fitting failures be reported? How about the different styles of plastic mechanical fittings? Do mechanical fitting failures in cast iron systems need to be reported?
All types of mechanical fitting failures should be included regardless of material. The objective of the data collection is to identify mechanical fittings which, based on a historical data, are susceptible to failure. The Advisory Bulletins, ADB-86-02 issued on February 26, 1986, and ADB-08-02 (73 FR 11695) issued on March 4, 2008, identified issues with mechanical fittings which could lead to failure. The bulletin advised operators to perform certain actions. Determining the apparent cause of these mechanical fitting failures is important to determine if and what type of additional actions may be needed if trends are identified. PHMSA intends for operators to report all types and all sizes of mechanical fitting failures which result in a hazardous leak. The failure can occur on a fitting connected to a pipe or a fitting that joins sections of pipe. Mechanical fittings include stab, nut follower, and bolt type fittings. The reporting requirements apply to failures in the bodies of mechanical fitting or failures in the joints between the fittings and pipe.

Operators are to report mechanical fitting failures as the result of any cause including excavation damage. Mechanical fittings are to be included regardless of the material they join. For example, include mechanical fittings which join steel to steel, steel to plastic, and plastic to plastic. Examples of the use of mechanical fittings may be found in the following applications: service tees, tapping tees, transition fittings, couplings, risers, sleeves, ells, “Ys”, and tees. Failures on fittings that are joined by solvent cement, adhesive, heat fusion, or welding are not to be reported as mechanical fitting failures.

PHMSA does not intend to collect information about failures of cast iron bell & spigot joints unless the leak resulted from a failure of a mechanical fitting used to repair or reinforce a joint.