Distribution Integrity Management Program

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Distribution Integrity Management Program

• Mike Beatty South Carolina Electric Gas
• Phillip Murdock Atmos Energy
• Southern Gas Association
• Operating Conference
• Houston, Texas
• July 18, 2006

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Distribution Integrity Management

• Mandated by Congress
• PHMSA did Phase 1 work in 2005
• Work products
• June 2005 Report to Congress
• DIMP report in December 2005
• 1.9 million miles of distribution pipelines
• Not like transmission IMP
• Concentrate on areas of biggest impact

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Distribution Integrity Phase 2

• Rulemaking ?Guidance Pipeline Safety
• (DOT PHMSA) (GPTC)
  Reauthorization
• __________________________________________________
  ____________
• Rulemaking (DOT PHMSA)
• Rule will have a significant impact
• Cost / Benefit Analysis will be required
• May contain appendices pending completion of
  Guide Material.
• Currently drafting (ex-parte mode) - Proposal
  will come out in October 2006
• Final rule - September 2007 Implement - 2009

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High-level Flexible Rule Seven Elements

• Develop written integrity program plan
• Know your infrastructure
• Identify the threats
• Assess prioritize risks
• Implement appropriate measures to mitigate risks
• Measure performance, monitor results evaluate
  effectiveness of program adjust if needed to
  improve
• Report results

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Distribution Integrity

• Guidance (GPTC)
• DIMP Task Group with Multi-Stakeholders
• Stand Alone Guidance v. Traditional Guidance
• GPTC is currently Discussing, Cussing and Editing
• How much is too little? Too much? Double edged
  sword!!
• Iterative Process. Guidance normally prepared
  after final rule.
• GPTC writing potential regulatory provisions.
  Inclusion in final rule (Preamble)? Adoption by
  states? States use as enforcement (protocols)
  guidance?

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Pipeline Safety Reauthorization

• May contain date certain for implementing DIMP
  rule?
• Language mandating installation of EFVs?
• Legislation on excavation damage prevention
• Incentives for states to increase effectiveness
• Continued funding for state One-Call grants
• Continued funding for Common Ground Alliance

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Improving Distribution System Safety

• Focus on
• areas of biggest impact

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What We Have Learned Total Incidents
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Corrosion (C), Material / Weld (MW), Equipment /
Operator Error (EOE)
Excavation/Mechanical Damage, Natural Force,
Other Outside Force
Source US DOT/OPS Reportable Incident Database
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Distribution Integrity ManagementBiggest Impact

• - Reduce excavation damage incidents -- 1
  Threat
• - Enhance leak management confidence
• - Other risk control (EFVs, repair/replacement,
  OM
• plan, emergency procedures)

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Excavation Damage Prevention

• Enhancements in
• Operator-excavator communications
• Partnership w/ all stakeholders
• Communications
• Training
• Public Education
• Enforcement
• Use of technology to improve one-call process
• Fair and effective enforcement
• Approaches
• Federal legislation (in 2006 reauthorization)
• Analysis of performance to verify effectiveness
• Use CGA Best Practices as basis for initial
  discussions
• Adjust if necessary

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Leak Management

• Is used to control risk
• Effective leak management programs
• Fewer incidents
• Still subject to significant variations due to
  diversity among operators
• What does a leak mean? Leaks caused by
  excavation damage does not indicate integrity /
  condition of an operators system!

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Leak Management Framework

• Locate -- Leak surveys other detection means
• Evaluate Assess severity of leak based on risk
  posed
• Act Remediate, or reduce risk and/or monitor
• Keep records Collect key data to increase
• knowledge of system
• Self-assess Measure performance adjust if
  necessary

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Excess Flow ValvesA Risk Control Option

• Installation should not be mandated
• Stakeholders on DIMP (state, industry public)
  agree on a risk-based approach installation
  decision criteria
• Industry prefers a recommendation for operators
  to consider EFVs based on risk
• Hope for increased use by operators

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Other Considerations

• Possible revision(s) to DOT Annual Report
• of Locates
• of Locate Tickets
• Leaks Repaired Requiring Immediate Response
• Leaks due to Excavation Damage
• Possible revision(s) to DOT Incident Report
• Collect Additional Data to Enable Root Cause
  Analysis
• Revising reports may be a separate initiative
  paralleling Distribution Integrity Management

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Resources

• SGA - Distribution Integrity Management Interest
  Group http//www.sgalink.org/forum/categories.cfm?
  catid35
• PHMSA/OPS (Cycla is a PHMSA contractor)
  http//www.cycla.com/opsiswc/wc.dll?webmainsubsys
  temhomesub22
• DOT Document Management System http//www.dms.dot.g
  ov click on "Simple Search" and type in 19854.

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Resources - SGA
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Resources - PHMSA
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Resources DOT
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?Q u e s t i o n sSpecial thanks to George
Mosinkis _at_ American Gas Association for his
contribution to this presentation
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Lets Take a BreakReconvene in Roundtable
Format