Some Dissatisfaction With DIMP

While distribution companies and state regulators seem to be satisfied with the general outlines of the proposed distribution integrity management program (DIMP) announced on June 25 by the Pipeline and Hazardous Materials Safety Administration (PHMSA), a number of questions are being raised by both groups about some of the proposal’s murky details.

The American Gas Association held a workshop in Chicago on the DIMP on Aug. 12 13. About 120 people attended, including PHMSA officials and representatives of the National Association of Pipeline Safety Representatives (NAPSR). There were rumblings in the corridors. Subsequently, both the AGA and NASR asked PHMSA to extend the comment deadline, which PHMSA did, from Sept. 23 to Oct. 23.

PHMSA’s proposed DIMP is an effort to force state regulators and intrastate pipelines to beef up their integrity management programs. To the extent that the proposed rule follows the recommendations in a 2005 report PHMSA published, which was based on ideas of stakeholders, it contains few surprises and its outlines are acceptable. However, there are more than a few sticking points among the details of the proposed rule. Philip Sher, program manager of Connecticut’s pipeline safety program and chairman of the NAPSR DIMP task group, says, “Questions about application of requirements can be tricky. Details can take a good rule and make it burdensome. We shouldn’t be looking at procedures that are 150 pages long.”

Chief among the concerns for state regulators and industry is PHMSA’s intention to require mandatory reporting of plastic pipe and associated fittings failures to the agency within 90 days. Currently, the Plastic Pipe Data Committee, of which the American Gas Association is the administrator, gets voluntary reports from owners of 83 percent of the plastic pipe miles in the United States, according to Phil Bennett, the senior managing counsel for the AGA. However, not all distribution companies have access to that data. Moreover, in the proposed rule, PHMSA wonders out loud whether the PPDC is “adequately objective to evaluate and report to the industry” or whether the agency should seek an independent third party to do the number crunching. PHMSA, which is a member of that committee, is concerned that companies without access to the PPDC data would lack the information necessary to do the kind of thorough risk analysis required by the DIMP. Bennett says AGA members oppose setting up a parallel, mandatory federal data base.

Sher says NAPSR has not taken positions yet on any of the issues raised by the proposed rule. However, speaking for himself, and based on his informal discussions with some state regulators, he wonders what PHMSA is trying to accomplish by requiring mandatory pipe and fitting failures. He questions whether there is a national problem that needs to be addressed and, if so, what that problem is; or are there simply several localized problems that have occurred that do not warrant new reporting requirements.

Sher also has some of the same questions that Bennett does about another somewhat controversial aspect of the proposed DIMP: it’s requirement that operators establish a “Prevention through People” program. Here, an operator would be required to include in its written IM program a separate section on “Assuring Individual Performance” in which they would identify 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). Distribution pipelines already must comply with a significant operator qualifications rule, and drug and alcohol testing requirements. “It is unclear what additional steps they want taken,” states Sher.

Bennett adds, “We thought the proposal was so vague it would cause problems at this point, plus industry believes we already address human factors through the current PHMSA requirements.”

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