DIMP Distribution Integrity Management

1. DIMPDistribution Integrity Management Ed Hatter, PESr. EngineerBlack Hills Energy1815 Capitol AvenueOmaha, NE 68102402.221.2546ed.hatter@blackhillscorp.com

2. Topics Covered Today • How will DIMP change the way your company performs operation and maintenance work? • Describe the progress your company has made so far in preparing for the new DIMP requirements? • What issues do you expect to receive the greatest focus as your company prepares its DIMP plan? • From an implementation perspective, what are the parts of regulation that you feel will be most challenging for operators?

3. How will DIMP change the way your company performs operation and maintenance work? First we need to look at what we currently do. • Focus is on keeping individual records of construction, maintenance, abandonments, maps, etc , to meet regulations timelines, • Threats: focus number and type of leak: line hits / corrosion / repairs / cost. • Annually determine which systems need to be replaced using a risk ranking according to materials, age, leaks, and information from Subject Matter Experts.

4. DOT192 After DIMP Regulation . . . • Learning new regulations and requirements 192.1001, .1003; .1005; .1007; .1009; .1011; .1013; .1015; .1017; .1019: • What it covers • New definition for “damage” • Timeframe – 18 months from FR to develop program • Covering all the elements of the program (9) • Reporting plastic pipe failures • Installing Excess Flow Valves • Filing new PHMSA reports • Keeping new records / database • Knowing when you can deviate from periodic inspections / process for waiver • LNG / Master Meters

5. After DIMP Regulation . . . • Writing a new plan: written plan on how to implement the DIMP Plan and identify records etc. to accomplish. • Creating a database for every pipeline in our system for each town: • identifying materials and threats by pulling information from individual records • maps, so that information can be accessed for analysis for whatever size of parameter, pipeline, town, service center, region or state to get us down to what a subject matter experts’ recommendations.

6. After DIMP Regulation . . . • Leak management program • Accelerated actions (A/A) for corrosion • Natural forces • Excavation damage • Other outside force damage • Material or weld failure • Equipment malfunctions • In-appropriate operation • Information from subject matter experts • Knowing all parameters when creating a database Identify and implement measures to address risks:

7. After DIMP Regulation . . . • Using a more formal-documented way of measuring performance: risk management, written process to measure performance that can be counted, tracked, monitored and supported e.g. leaks and locate tickets • Benchmarking historical data: current records to create a baseline to establish historical benchmarks, e.g. using data from last 4 years of annual reports and create charts, create numerical data comparisons • Validating or challenging what numerical data is indicating. • Focusing on methods / practices and procedures

8. After DIMP Regulation . . . • Asking more questions on threat analyses to drill down to find root causes • Annually review written plan content to ensure it remains accurate and appropriate • Analyzing the effectiveness of risk management techniques or practices or accelerated actions adopted to respond to specific threats • Continually re-evaluating threats / risks on entire system and consider relevance of threats in one location to other areas • Evaluating the effectiveness of the program for assuring individual performance to reassess the contribution of human error.

9. After DIMP Regulation . . . • Conducting plan reviews after a plan milestone e.g. major pipe replacement program • Updating databases periodically (annually) • Reviewing performance measures – different risk ranking practices or management • Keeping records that document a review was performed even if no changes were made • Reporting results to PHMSA: Incident Reports and Annual Reports are being revised to reflect DIMP requirements

10. Describe the progress your company has made so far in preparing for the new DIMP requirements? • The focus has been on what type of database should be created – web based? • Who should be able to access? • What parameters should be known up-front, etc.

11. What issues do you expect to receive the greatest focus as your company prepares its DIMP plan? • Time and resources. To create a database, the IT department needs to be a part of the solution. • Deciding how and who will collect the data for a multi-system pipeline and the manpower to get it into a database.

12. From an implementation perspective, what are the parts of regulation that you feel will be most challenging for operators? • Creating the database • Training field operations on the concept and practices needed to implement DIMP • Manpower in Engineering to oversee the process and implementation • Cost

13. ? Questions References: Lane Miller presentation GPTC DIMP Guide