Are You Ready For DIMP?

By Eric Kirkpatrick, Structural Integrity Associates, Inc | November 2009 Vol. 236 No. 11

In August, the Pipeline and Hazardous Materials Safety Administration (PHMSA) informed the Technical Pipeline Safety Standards Committee (TPSSC) that the proposed rule on Gas Distribution Pipeline Integrity Management (commonly referred to as DIMP) has been approved by the DOT and sent to the Office of Management and Budget (OMB). The OMB is expected to review and approve a DIMP rule in the 4th quarter of 2009. Perhaps by the time you read this the final rule may already be published.

The Notice of Proposed Rulemaking (NOPR) issued in June 2008 requires each operator of a gas distribution system to fully implement an integrity management program within 18 months that contains the following elements:

  • Knowledge
  • Identify Threats
  • Evaluate and Prioritize Risk
  • Identify and Implement Measures to address Risk
  • Measure Performance, Monitor Results, and Evaluate Effectiveness
  • Periodic Evaluation and Improvement
  • Report Results

Eighteen months will go by very quickly! So, what can operators be doing right now? The following is provided to help gauge your readiness:

Knowledge
The NOPR requires that operators demonstrate an understanding of their gas distribution system. Operators will therefore want to assess the manner in which they collect data, and subsequently how they turn that data into information and knowledge that can be used in their Integrity Program.

Operators will want to survey and determine what information they already have and in what format it exists (paper, spreadsheet, database, etc.). The NOPR requires that operators gather data from the following sources to indentify existing and potential threats: incident and leak history, corrosion control records, continuing surveillance records, patrolling records, maintenance history, and ‘‘one-call’’ and excavation damage experience.

It is suggested that operators perform a gap analysis between the data (and data format) they currently have available and what they ultimately desire to support their integrity program. In doing so, they will want to consider the following questions: