Distribution Integrity Management

Distribution Integrity Management John Erickson, PE American Public Gas Association

Distribution Integrity Management Rule

History & Future • 2001 – Liquid Integrity Management Rule • 2003 – Transmission IMP Rule • 2004 – DOT Inspector General Testifies • 2005 – PHMSA Issues Phase 1 Report • 2006 – GPTC Prepares Guidance • 2008 – Notice of Proposed Rule 6/25/08 • 2009 – Expect final Rule • 18 months for implementation

Phase 1: DIMP Structure • 1. Development of an integrity management plan • 2. Know your infrastructure • 3. Identify threats (existing and potential) • 4. Assess and prioritize risk • 5. Identify and implement measures to mitigate risks • 6. Measure and monitor performance and results • 7. Report results

Know Your Infrastructure • Material(s) of construction • Leak history • Repair history • Inspection records: • Cathodic protection • Leakage surveys • Exposed pipe inspections

Identify Threats • A “threat” is something that can lead to an unplanned release of gas • Phase 1 identified 8 threats: • Corrosion Material or Welds • Natural Forces Equipment • Excavation Operations • Other Outside Force Damage Other

Assess and Prioritize Risk • Two general approaches: • The Subject Matter Expert method. • Review and ranking by the persons most knowledgeable about the system • Algorithm methods. • Numerical scores based on scores assigned to various attributes of the system • Final determination by SME’s

Implement Actions to Reduce Risks • DIMP does not presume that additional actions will always be required.* • GPTC offers suggestions for each threat • Operators may elect to continue existing inspection/repair/replacement programs, choose actions from the GPTC list or develop their own actions to address threats * See next slide for the exception

*Except For Inappropriate Operation • Each plan must have a section titled “Assuring Individual Performance” • List risk management measures to evaluate and manage the contribution of human error and intervention to risk (e.g., changes to the role or expertise of people), and implement measures appropriate to address the risk.

Continued • Also list existing programs the operator has implemented to comply with • Sec. 192.614 (damage prevention programs); • Sec. 192.616 (public awareness); • Subpart N (qualification of pipeline personnel), • 49 CFR Part 199 (drug and alcohol testing).

More Specific Requirements • Excess Flow Valves on new and replaced single residential services > 10 psig • Leak classification system • Locate the leak • Evaluate its severity • Act appropriately to mitigate the leak • Keep records • Self assess

GPTC Leak Grading • Grade 1 – Immediately hazardous to the public or property – Fix immediately • Grade 2 – Not immediately hazardous – may be repaired or monitored for limited time • Grade 3 – Not immediately hazardous and may be monitored indefinitely

Fix All Leaks • Will the rule require grading even if all leaks are immediately repaired? • APGA will urge PHMSA to accept find and fix as an acceptable alternative • Operators would still have to track immediately hazardous leaks for performance measurement

EFV Requirements • Congress instructed DOT to include a June 1, 2008 deadline in DIMP rule • PHMSA has written to states urging them to encourage operators to install EFVs June 1 • PHMSA has issued a Advisory Bulletin • Not a legal requirement, but APGA urges operators to meet the June 1 deadline

EFV Installation Requirements • New and replaced only (no retrofit) • Services to single residences (not branched services, not multi-family, not commercial or industrial) • Continuously operating <= 10 psig • Would not interfere with clearing liquids from the service and no history of plugging due to debris in the gas

EFV Considerations • Recommend closure flow 50% greater than connected load on service • New utilization equipment affects service line design • Tank-less water heaters draw as much as 5 times more gas than conventional water heaters • Home electric generators • Consider ¾” or 1” PE and 800 cfh EFV rather than ½” and 300/400 EFV

Measure and Monitor Results • How will you measure whether your program is successful at reducing risks? • Internal and external performance measures • Internal – Used by the utility • External – Submitted to the State/Federal regulators

External Measures – Reported to State & PHMSA • Number of hazardous leaks eliminated by cause; • Number of excavation damages; • Number of excavation tickets; • Number of EFVs installed;

Internal Measures • Total number of leaks eliminated by cause; • Number of hazardous leaks eliminated by material; and • Any additional measures to evaluate the effectiveness of the operator's program in controlling each identified threat.

Plastic Pipe Failure Reporting • Report detailed analysis of all failures on plastic pipe and components within 90 days • location of the failure in the system, • nominal pipe size, • material type, • nature of failure, • pipe manufacturer, lot number and date of manufacture, and other information that can be found in markings on the failed pipe

Why? • Operators with > 70% of installed plastic pipe participate in the existing voluntary reporting program • A team of government and industry experts reviews data every 6 months • PHMSA has issued advisory bulletins based on the voluntary program

Why? • According to PHMSA, small utilities need the raw data so they can do their own analyses • Real reason: Some state and federal regulators want access to the raw data • APGA opposes mandatory submission – poses a burden on small systems with no benefit (getting 100% will not provide better statistical certainty of results)

Recordkeeping • 10 years for performance measures • For the life of the system for: • Rationale for all changes to the written IM plan • All documents used in developing threat assessments • A written procedure for ranking the threats

Continuing Improvement • Operators must perform a complete program evaluation at least every 5 years • If performance measures show improvement, no further action required, however, • If performance measures show no progress or declines, operators must modify DIM Plans

Master Meter & LP Piping Operators • Infrastructure knowledge • Identify threats • Implement measures to mitigate risks • Measure performance, monitor results, and evaluate effectiveness. # of leaks repaired by cause • Periodic evaluation and improvement

MM & LP Records • The operator must maintain, for the useful life of the pipeline, the following records: • A written IM program; • Documents supporting threat identification; • Documents showing the location and material of all piping and appurtenances (for pre-existing pipelines, as much as is known)

GPTC Guidance • Geared toward larger operators • Guidance only, not mandatory • Lists of infrastructure knowledge elements • Lists of questions for threat assessment • Lists of possible additional measures • Lists of possible performance measures • Published along with final rule

Introducing SHRIMP! • Simple, Handy, Risk-based Integrity Management Plan

SHRIMP • Envision a software product similar to tax preparation software (TurboTax) • SHRIMP will ask the user a series of questions about the system and its inspection and maintenance history • Questions will change based on answers • Output will be a nearly complete DIM Plan

SHRIMP Timing • Due 6 months after final rule • GOAL: Have SHRIMP trial version available when final rule is issued. • That way utilities can decide whether to use SHRIMP or other means to develop DIMP

SHRIMP Development • Advisory Group made up of state regulators, federal regulators and industry • Technical Toolboxes is software developer • Heath and Associates, Technical Consultant • Viadata, Technical Consultant

Questions? • jerickson@apga.org • 202-464-0834 • www.apga.org

Distribution Integrity Management