The Source - Fall 2008 - (Page 28)

 NEW DIMP REGULATIONS, from page 27 special field surveys, and information gathered through routine operation and maintenance activity. Operators may mitigate risk by treating their distribution system as separate segments rather than as a single system, if its parts are significantly different in terms of pressure, materials, age of infrastructure, and maintenance histories. An operator’s risk analysis might not necessarily result in replacing pipe. There are other controls that can be put in place to mitigate risk. Through their risk analyses, operators may determine that no additional actions are required. Many operators are already taking steps to address problem areas of their systems, and these actions may be sufficient to address identified threats. However, the DIMP rules do require operators to be proactive in identifying and managing risks to their systems. For example, in a leak management program, five elements are required, expressed in an appropriate acronym: Key Elements of DIMP 1. Know the infrastructure 2. Identify threats 3. Assess and prioritize risks 4. Identify and implement appropriate measures to mitigate risks 5. Measure performance and monitor results 6. Evaluate program and change as needed 7. Periodically report performance measure they’re improving the safety of their system. There is flexibility in the determination of what specific internal and external performance measures are appropriate, such as tracking the number of corrosion leaks or tracking the number of third-party hits to measure the effectiveness of damage prevention programs. If operators show, for example, that they are reducing the number of leaks over a given period, an auditor should see that as positive. If the number of leaks is still rising, then the operator will have to take additional effort. According to the DIMP rules, for each significant threat identified to a system, one or more performance measurements must be identified to help the operator determine if they are achieving the desired results. Best practices The term “distribution integrity” may be new to the public gas industry, but the concept of risk management programs is not. From leak and corrosion management programs developed in the 1970s to the more recent “call before you dig” and repair/replace programs, best practices have evolved in the gas industry, and some aspects of the DIMP regulations may already be covered by an operator’s existing procedures. The difference is the degree of formalization. For example, almost all public gas systems perform some type of leak surveys, pipe surveys, and line patrolling, but these operations may have been performed by different groups in the past with little interaction. That may have to change. The DIMP regulations give the public gas industry a clearer picture of the steps required by regulators to help ensure continued safety of their gas distribution systems. DIMP brings safety to the forefront and is making the risk management, documentation, and analysis more formal with the possibility of formal repercussions. Despite being a high-level, flexible regulation, DIMP may still require increased expenditures for compliance. States like Ohio that have taken proactive steps for cost recovery are ahead of other areas anticipating the requirements of DIMP. A number of utilities have partnered with EN Engineering on everything from developing programs to risk analysis to replacing pipe. Each system has its unique needs, but they are all working within their budgets and doing what they can to make their systems safe and more reliable for their customers. Glen Armstrong is senior technical specialist with EN Engineering, a full-service pipeline engineering design and consulting ﬁrm located in Woodridge, Il. Armstrong participated on the Distribution Integrity Phase 1 study team and served as the chairperson of the Gas Pipeline Technical Committee task group thta developed and provided guidance for the DIMP regulations. Jenny Hudson is senior project manager with EN Engineering. She leads integrity management activities and continues to work with multiple utility clients and industry organizations to develop IMP plans and provide guidance for state and federal PHMSA regulatory audits. Locate the leaks in the distribution system Evaluate the action or potential hazards associated with the leak Act appropriately to mitigate these hazards Keep records Self-assess to determine if additional actions are necessary to keep people and property safe Measured improvement One expected outcome of DIMP is continuous improvement. Operators will have to define some internal performance measures and examine them on a regular basis to see if 28 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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