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Gas Distribution Integrity Management

by John A. Jacobi, PE
Community Assistance/Technical Services Manager, PHMSA Southwest Region

Last Spring (see Volume 2, Issue 2), I wrote about proposed new rules affecting more than two million miles of natural gas distribution systems that directly serve homes, schools, and businesses that were expected “late summer.” This year, late summer came December 4th (Don’t ask!). See Docket No. PHMSA-RSPA-2004-19854 found at www.regulations.gov for the 32 page announcement of the “Final Rule” in the Federal Register. PHMSA received 143 letters commenting on the proposed rule: 12 from national and regional trade associations (including the National Association of State Pipeline Representatives [NAPSR]); 107 from municipal and non-municipal distribution system operators; 15 from state pipeline safety agencies; and 9 from other stakeholders. As with almost every Federal Final Rule, the preamble contains a detailed discussion of every comment and how the Final Rule changed (if it changes) as compared to the proposed rule. The following is a very brief summary of the changes by Topic as numbered in the Notice of Final Rulemaking:

1. Plastic Pipe Reporting – eliminated except for coupling failures
2. Performance Through People (PTP) – eliminated (covered by other regulations)
3. “Damage” Definition – all “hits”, follows CGA’s DIRT Model
4. Implementation Time – 18 months (develop & implement program by August 2, 2011)
5. Rule Structure & Implementation – “plain English” (question & answer), all references to “processes” deleted
6. Alternative (risk-based) Intervals – equal or improved safety based on proposal to primary regulatory authority who has responsibility to determine safe intervals
7. Master Meter and Small LPG Operators – limited requirements and simplified programs
8. Transmission Lines operated by distribution operators – still subject to other Part 192 Regulations (requirements not changed because of DIMP)
9. Leak Management under DIMP is not the same as leak surveys under §192.614, Damage prevention requirements will be addressed under §192.614 – not DIMP
10. Hazardous Leak Definition – use Gas Piping Technology Committee (GTPC) guidelines
11. Required Documentation – enough to demonstrate compliance, 10 year minimum retention
12. Excess Flow Valves – only single-family service lines meeting certain criteria
13. Guidance – GTPC guidance for large operators, PHMSA to provide guidance for Master Meter and LPG operators
14. Leak Monitoring Program – required unless all leaks repaired when found
15. State Authority – states with PHMSA certified programs (most states) have the authority and obligation to inspect operator compliance the flexibility to determine how best to do it in each individual circumstance
16. Program Evaluation & Improvement – periodic re-evaluations (at least every five years), improvements as needed, consideration of threats required
17. Permanent Marking of Plastic Pipe – not included, will be addressed outside this rulemaking
18. Continuing Surveillance – §192.613 still applies
19. Information Gathering – understanding of distribution systems must be from “reasonably available information” and no list of examples is provided
20. Knowledge of Pipeline – 5 separate issues – read the preamble
21. Threat Identification – one-call experience no longer listed as a separate source (redundant), language added to indicate list of sample sources not exclusive
22. Risk Assessment – not necessarily geography based, potential threats must be considered, mathematical process not necessarily required, must consider both likelihood and consequences
23. Performance Measures – old pipe vs. new pipe not required, one-call tickets required, leaks required, number of incidents required, generally required on annual reports
24. Regulatory Analysis (Cost & Burden) – PHMSA adjusted its assumptions and believes the analysis indicates a net positive benefit
25. DIMP for New Pipelines – this rulemaking intended only for existing systems (does not apply to new construction)
26. Annual Report Form – all data will be reported via the annual report, revision of the annual report is by a separate rulemaking.

The Notice of Final Rulemaking also addresses comments by the National Transportation Safety Board (NTSB – when the NTSB speaks, PHMSA listens!) and PHMSA’s own Technical Pipeline Safety Standards Committee. The actual regulatory language is only two pages! All the rest is explanation of how PHMSA got from last year’s Notice of Proposed Rulemaking (NOPR) to the Final Rule. On balance, PHMSA made a significant number of changes based on the comments. How many other Federal Agencies do that? All in all, the already good record of distribution systems should improve. Stay tuned, the dust hasn’t had time to settle yet.