In talking points for the upcoming Distribution Integrity Management Program, the Southern Gas Association pointed out, “When the pipeline safety code was adopted in the early 1970s it was reasonable and prudent to adopt a consistent set of federal pipeline safety standards for the entire nation.”

In a regulatory sense, that “reasonable and prudent” course is completed by the arrival of DIMP in February – fully evaluated, examined and approved.  DIMP is the next phase of the Pipeline Safety Act of 2002; but more important, it is really one of the most momentous additions to federal pipeline regulations since the process began four decades ago.

Momentous because it will affect so many of you who operate inside the city gate. Its impact will be time-critical, too: By August 2, 2011, local distribution companies and other operators have to have a written integrity management plan in place and implemented.

It’s about two million infrastructure miles
The pipelines targeted by DIMP are inside-the-citygate, low-pressure lines made of plastic or black steel. Nationally, it’s a “system” that is made up of 1.2 million miles of mains and 800,000 miles of smaller lines. These low-pressure lines tend to fail as leaks instead of the ruptures to which high-pressure transmission lines are subject.

Annually, there are more injuries and deaths that are attributed to distribution pipeline incidents than any other segment of the national pipeline system. These are more localized incidents which don’t get the national press attention that a transmission pipeline incident or failure would garner.

Although the American Gas Foundation evaluated the distribution experience from 1990 to 2002 and found that distribution pipelines are as safe as transmission pipelines,   distribution pipelines’ accidents were more serious because of their location in urban and built-up areas. The low-pressure lines have very rarely failed catastrophically. Instead, they have failed through leakage caused by corrosion, third-party construction damage or damage from work being done by private citizens on their own property.

At the same time, there is no system in this “system.” It’s thousands of natural gas operators, almost 10,000 of you, from large local gas utilities to smaller companies, LPG operators, small master meter and modest LPG-system operators that could be privately held or the responsibility of municipalities.

Despite the extensive coverage of DIMP by industry trade associations, regulatory entities and publications, you “10,000” cannot help but have various levels of awareness about the actual demands coming down the pike in terms of DIMP. (Some of the largest LDCs did participate in the rule-setting, which is actually good news – the Federal government appears to have gotten this one properly framed.)

So: You are among hundreds of small- to medium-sized systems and municipalities operating small- to medium-sized systems without a lot of money for or experience with the kind of planning for risk reduction, which will be demanded by DIMP.

Recapping DIMP’s risk-reduction demands
Whatever your level of DIMP awareness, a review of its seven elements is worthwhile. You must have:

1. Knowledge and understanding of your distribution system
2. Identify threats to the system
3. Evaluate these threats and rank the associated risk
4. Identify and implement measures to mitigate these risks
5. Measure the performance, monitor results and evaluate the effectiveness of your risk mitigation measures
6. Periodic evaluation and improvement
7. Reporting the results.

How many times does the word “risk” or “threat” occur in these bullet points? Creating a complete program means having measures in place to address specific risks to your system, monitoring measures in place that capture the overall effectiveness of your integrity management program and a written plan to cope with it all.  

With DIMP, risk management is forced inside the citygate and you have to shoulder the load. Among all the others, two features stand out: Increased data demand and compliance help.

The drive for more – and better – data
Maybe you already have every bit of the extensive information that your forthcoming new IM plan is going to require. But…maybe not. The intensive assembly of operations and maintenance (O&M) data and the ongoing collection discipline required to maintain it may have been beyond the scope of your operations and budget.

Like many other PHMSA regulatory initiatives, data is going to be crucial for effective DIMP compliance. It will drive how you are going to accomplish risk management and how you will report the necessary metrics.

You will have to identify gaps in your current information; establish what data will be most valuable in meeting new regulations; write down and review the processes and procedures for leak tracking and reporting (very important), maintenance operations, new installations, pipe exposures, third-party damage and other activities.  All this data must be used to define – in writing – how you are going to [a] improve your processes to [b] reduce risks to your constituents and consumers.

Part of the risk-reduction equation is the need to eliminate subjectivity and inconsistency from integrity management. At bottom, that elimination is what the systemization of your data will accomplish.

For hands-on compliance, familiarity is a benefit
But this is not just about data. Not even close. With DIMP, the level of scrutiny is going to rise steeply, far above what you are used to.  In this, as in DIMP’s other demands, a recurring comment is, “We aren’t yet sure what we’re supposed to do.” Well, fasten your seatbelts.

LDC operators may not have an equal level of experience working with federal and state regulators. Your pipeline system, small, medium or large, may have been audited before but it is likely to be part of a more compact operation, perhaps with fewer personnel. (It is even possible that your entire focus is not on the gas system itself, but on your total operation.)

When your problems – operations, inspection, maintenance, etc. – were purely local, it made sense to work locally. With DIMP, the challenge you face is federally mandated. You may benefit from a compliance partner with broader, deeper experience.

EMS has worked closely with local, state and federal compliance authorities for years. It is one example of a nationally-based organization that knows all the rules, has all the hands-on experience. It knows the systems and the regulations from wellhead to citygate to burner tip. EMS experience, for example, encompasses:

1. Collection and maintenance of data
2. Creation and presentation of IM plans
3. Systematized, in-the-field maintenance
4. Complete integrity management.

This represents a unified program option rather than a piecemeal approach, a hands-on solution from one source.

Use a proven partner, put time on your side
At the outset, the DIMP rule may be financially burdensome. It may require many workhours to initially implement, and that means money.  The ultimate result of compliance will provide you with much better – and better organized – knowledge of your system, offering greatly enhanced safety to your customers and the general public.

Partnering with a one-stop compliance resource would make your progress to completing your new integrity management program smoother. It can generate budget savings instead of massively increased expenditures. And it can ensure you make it to the 8/2/2011 deadline on time.

Learn more about EMS USA's DIMP services by clicking here.