US Distribution Regulatory Requirements

Incorporating a Distribution Integrity Management Program for Pipeline Safety

Since 2010, federal regulations (49 CFR 192 Subpart P) have required distribution pipeline system operators to have a Distribution Integrity Management Program (DIMP) and associated written integrity management plan. These regulations prescribe the elements of a DIMP and require pipeline operators to evaluate their DIMP every 5 years, at a minimum. State and municipal regulators can also mandate additional regulations and requirements for the gas distribution sector at their discretion.

The challenge for operators is having in-house expertise and knowledge of the requirements in developing and actively managing an effective DIMP and to remain compliant with the regulations. Since a DIMP is mandatory, operators must develop, manage, and periodically evaluate an integrity management program internally, or source and obtain external support.

Whether an operator is large or small, each benefit from developing a robust integrity management program to regularly review risk assessments, remain regulatory compliant, mitigate impacts to the environment and ensure public safety and the company’s reputation.

Due to the nature of distribution mains, service lines, and facilities being in higher population density areas, and sometimes within urban dwellings, an incident can have a significant impact on public safety. There also can be a significant financial cost from any incident. Various threats for the cause of an incident include ground movement, corrosion, joint and fitting degradation, or 3rd party damage.

While ensuring public safety, distribution companies must also use limited resources to efficiently manage costs to monitor and repair aging pipeline infrastructure, such as cast-iron pipe. The objective is to implement a cost-effective, risk optimized mitigation strategy.

An effective Distribution Risk Program includes a forward looking, predictive approach and related mitigation strategies to increase system safety and reliability.

Key Elements for an Effective Distribution Risk Program

  1. Investigate root causes for past events, by operator and industry, including catastrophic as well as less significant events (leaks), to understand how gas networks behave and change over time.
  2. Identify “threat scenarios” to the gas distribution network that lead to catastrophic events, including high risk assets, failure modes and consequences.
  3. Quantify the probability of each scenarios and identify which assets are most vulnerable, including asset type, condition, and location.
  4. Establish mitigation strategies, including prevention, detection, and response activities, that most effectively mitigate the risk of gas events, and understand the risk reduction benefits of each mitigation options.
  5. Implement supporting processes and tools to sustain the process, including data analytics and mitigation analysis, and ensure clear accountabilities and responsibilities exist.

Whether an operator is large or small, each benefit from developing a robust DIMP. Furthermore, as technology advances, new methods are being introduced that involve a quantitative approach in the development and management of risk. Data integration is key to risk management.

Dynamic Risk partners with operators to analyze and define the primary risk drivers and confirm the appropriate actions for risk reduction. Contact us today to discuss how our team of experts can best support your integrity management needs for Gas Utilities and Distribution assets.