I was a member of the joint National Association of Pipeline Safety Representatives (NAPSR) – PHMSA Distribution Integrity Management (DIMP) Committee from 2010-2022. This is the group that developed the guidance for the DIMP program and developed the inspection questions. Over the years, one of the top issues inspectors told the committee was operators using a program like SHRIMP (“Simple, Handy, Risk-based Integrity Management Plan”) to develop their plan and then set it on the shelf. Many times there would be no training of operator personnel as to the requirements of the DIMP plan and no training in updates to the plan. More often than liked, operator’s DIMP plans were pulled off the shelf only for annual updates and inspections. Throughout the year, there would be little engagement of the operator’s personnel in performing the requirements of the plan.
I encourage you to conduct training with your gas techs in the requirements of your DIMP plan and to update this training annually as the DIMP plan is updated. If you are busy, I can help with this training.
A major update to DIMP regulations is coming soon. I have attached the Notice of Proposed Rulemaking dated September 7, 2023 FYI. The major proposed changes (triggered by the overpressure incident of a low pressure gas distribution pipeline in 2018 in Merrimack Valley) are:
- 1007 (a)(3) Identify additional information needed and provide a plan for obtaining that information: Added the records specified in § 192.638(c)) which are pressure control location, attributes of regulators, overpressure configuration
- 1007 (b) Identify threats. Added to natural forces threat definition: natural forces (including extreme weather, land movement, and other geological hazards). Added material (including the presence and age of pipes such as cast iron, bare steel, unprotected steel, wrought iron, and historic plastics with known issues). Added: over pressurization of low pressure distribution systems
- 1007 (c) evaluate and rank risks. Added paragraph 2 on certain pipe with known issues. Added paragraph 3 covering low pressure distribution systems.
- 1007 (d) Identify and implement measures to reduce risks. Added paragraph 2 on minimization of over pressurization of low-pressure distribution systems
When this proposed rulemaking becomes a final rule, I would be happy to assist you in modifications to your DIMP plan to ensure compliance.
This month’s special: 40 hours of consulting time including travel anywhere in Florida for $2,750 all in cost to you covering consulting fee and travel expenses. I will cover whatever you want in the scope of my work which includes the areas below. You can ask me any questions in these areas and we can discuss compliance options to improve your compliance program.
- Mock pipeline safety compliance audits to prepare for regulatory inspections
- Pipeline safety compliance manual reviews and edits
- Compliance audit support
- Pipeline safety compliance training
- Pipeline integrity data review/processing