The Source - Fall 2008 - (Page 26)

the pipeline New DIMP regulations promote risk analysis By Glen Armstrong and Jenny Hudson, P.E. Over the past three years, the American Public Gas Association (APGA) has helped develop guidelines for the integrity management of nearly 2 million miles of gas distribution piping in the United States. The goal: improving public safety, while intelligently minimizing the potentially prohibitive expense and complexity that new regulations could have on APGA membership and the public gas industry. These guidelines—the Distribution Integrity Management Program (DIMP) rules—are expected to be issued this summer. Issued by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), the DIMP regulations follow those established by the same authority in 2001 for liquid pipelines and in 2004 for natural gas transmission pipelines. However, the DIMP regulations are far less prescriptive and have much greater flexibility for natural gas distribution operators than the regulations affecting the transmission segment. The very flexibility of implementation—while certainly welcome—may pose problems for APGA members in terms of interpretation, because regulatory oversight and enforcement varies from state to state. The manner in which these rules will be enforced is probably what concerns operators the most. Although the DIMP regulations are set at the federal level, it is up to the state regulators to audit the local operators’ DIMP programs. Every system audit will be different. For example, the regulators in Arizona may be looking for very different things than those in Illinois. Operators of gas and liquid transmission pipelines have faced fines—large fines in some cases—for failures of implementation. Such fines are not anticipated with the DIMP rules, at least not at the outset. It is safe to assume that the rules will be enforced, as regulators themselves normally define the reporting requirements and time frames. Although the specifics of regulatory enforcement of DIMP are yet to be determined, there is no question that failing to comply with DIMP will have its consequences. Of particular concern is the consequence of how and where local resouces are directed. Start with risk analysis At the very minimum, every operator must understand the DIMP rules, write a program and do a risk analysis—a big issue for operators. Performing the risk analysis will help operators prioritize and devote attention to their highest areas of risk. It is anticipated that most operators will use a combination of internal and external subject matter experts and mathematical models to assess and prioritize their risks. While the term “subject matter experts” can appear daunting, it really refers to those individuals most familiar with the operation and maintenance of this system—your maintenance staff. To assist smaller gas systems in developing programs that comply with DIMP, the APGA board of directors is developing a software program through the APGA Security and Integrity Foundation. The program (internally referred to as “SHRIMP” for Simple, Handy, Risk-based Integrity Management Plan) now in a beta format, is expected to be available by the end of 2008 and can be used to complement internal expertise and outside consultants on developing compliant plans and analyses. Diﬀerent integrity management approach for distribution piping In the regulations for gas transmission pipelines, operators were required to identify high consequence areas where population density could result in greater possibility of damage and injury and then to devote attention to the highest risk areas. This required © Dark3D/www.dreamstime.com. 26 THE SOURCE | THE VOICE AND CHOICE OF PUBLIC GAS

Table of Contents Feed for the Digital Edition of The Source - Fall 2008

The Source - Fall 2008 Contents First Person APGA Awards APGA Events Overview Up Next in THE SOURCE Grassroots Connections Climate Change Legislation Market Transparency: An Insider's View Legislative Outlook The Pipeline Marketing Matters Advertisers' Index At Last

The Source - Fall 2008

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