The “Pipeline Inspection, Protection, Enforcement and Safety Act of 2006” requires the Department of Transportation (DOT) to establish a regulation prescribing standards for integrity management programs for distribution pipeline operators. DOT formally proposed the Distribution Integrity Management Program (DIMP) rule in June 2008.
Much of the proposed rule is consistent with the themes and conclusions drawn by the DIMP Phase 1 Report, Integrity Management for Gas Distribution Pipelines, issued by DOT in December 2005. The level of documentation required in the proposed rule placed an undue burden on industry, as the documentation required did not account for the diverse nature of distribution systems. AGA proposed that operators be required to document significant changes made to their DIMP programs, not all changes. The proposed rule stipulated that operators submit plastic pipe data to a mandatory PHMSA database. AGA stated that the existing Plastic Pipe Database Committee (PPDC), which consists of members from industry and the regulatory community, adequately addresses DOT’s concerns. In addition, the proposed rule included prescriptive language to address human factors and risk mitigation. Congress only mandated DOT to address human factors as it applies to control room management. AGA stated that programs and regulations are already in place to address human factors on distribution system operations and there is no basis for fatigue management under DIMP. The proposed rule included language for operators to use technology and data analysis to support alternate inspection intervals. AGA is supportive of the alternate inspection intervals concept proposed by the DOT.
A task group of the Gas Piping Technology Committee (GPTC), with participation by many AGA member companies, developed a guidance document that will help clarify the requirements of the DIMP rule. The GPTC guidance document has been drafted and will be revised, as necessary, to conform to the final rule.
AGA held a workshop in August 2008 for industry to voice concerns regarding the DIMP proposed rule. DOT and the National Association of Pipeline Safety Representatives participated in the workshop. AGA submitted its comments on the proposed rule in October 2008. DOT’s Technical Pipeline Safety Standards Committee (TPSSC) met in December 2008 to discuss the proposed rule. During the December meeting, the TPSSC voted to support a DIMP final rule that addresses the concerns raised by AGA. The final rule is expected to be promulgated in late 2009.
AGA will continue its advocacy efforts on this critical issue to ensure the final regulation is reasonable, practicable, and cost-effective for operators. AGA will continue to provide support to the GPTC as modifications are made to DIMP guidance document. AGA will provide assistance as members begin to prepare for the final DIMP rule. AGA will organize workshops and other educational forum to inform members about the work that industry is doing to implement DIMP concepts and regulatory requirements.
AGA Contacts: Phil Bennett, (202) 824-7339, firstname.lastname@example.org; Kyle Rogers, (202) 824-7218, email@example.com