DIMP Implementation Using the
NGA/SGA Plan
Managing CSEF Materials
Western Regional Gas Conference
Eric Kirkpatrick, P.E.
August 24, 2010
SLIDE 1
Gas Distribution Integrity Management
49 CFR, Part 192, Subpart P
§192.1005 No later than
August 2, 2011 a gas
distribution operator must
develop and implement an
integrity management
program that includes a
written integrity
management plan
SLIDE 2
Gas Distribution Integrity Management
Develop and fully implement a written IM Plan. Plan
Elements inlcude:
• Knowledge
• Indentify Threats
• Evaluate and Rank Risks
• Identify and Implement Measures to Reduce Risks
• Measure Performance, Monitor Results, Evaluate
Effectiveness
• Periodic Evaluation and Improvement
• Report Results
SLIDE 3
NGA and SGA Collaborative
• Northeast Gas Association and Southern Gas
Association formed a collaborative to develop a
framework document and guidelines for a distribution
integrity management plan
– 58 companies thus far
• Collectively these 58 companies serve more than
55% of the distribution customers in the U.S.
• Structural Integrity Associates is the principal author
• NGA and SGA DIMP Steering Committees and
Member companies participated and provided
comments and input during development
SLIDE 4
Companies who are using the Plan
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SLIDE 5
National Grid
NiSource
Atmos Energy Corp
AGL Resources
Nicor Gas
ONEOK, Inc.
Southwest Gas Corp.
Ameren
Puget Sound Energy
Dominion East Ohio
Consolidated Edison of New York
We Energies
Piedmont Natural Gas
Questar Gas
Puget Sound Energy
National Fuel
Questar Gas
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NW Natural
Laclede Gas Company
Baltimore Gas & Electric
New Jersey Natural Gas Company
Alabama Gas Corp
SCANA
TECO Peoples Gas
Memphis Gas, Light & Water Division
LG&E Energy, LLC
Avista
NSTAR Gas
South Jersey Gas Company
Rochester Gas & Electric Corp.
New York State Electric & Gas Corp
Yankee Gas Services Company
Unitil
Companies who are using the Plan
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SLIDE 6
Equitable Gas
DTE Energy – Michcon
Southern Connecticut Gas Company
Connecticut Natural Gas Corp
Arkansas Western Gas Company
Entergy New Orleans, Inc.
Orange & Rockland Utilities, Inc.
Mobile Gas, a Sempra Company
Florida Public Utilities Company
Central Hudson Gas and Electric
Corp
Arkansas Oklahoma Natural Gas
Corp
Roanoke Natural Gas
New England Gas Company
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City of Richmond, VA
Vermont Gas Systems, Inc.
Berkshire Gas Company
City of Holyoke Gas and Electric
Department
St. Lawrence Gas Company, Inc.
Corning Natural Gas Corporation
Westfield Gas and Electric Light Dept
Norwich Public Utilities
Wakefield Municipal Gas and Light
Dept
Middleborough Gas and Electric
Department
Maine Natural Gas
Blackstone Gas Company
Plan Framework & User Guide
PLAN FRAMEWORK
SLIDE 7
DIMP User Guide
Written IM Plan Framework
• A Generic Framework
• High Level & Flexible
• Applicable to both the largest and smallest
operators ( 3.4 million to 1,400 customers)
• Operator customizes by populating Appendices
material
• Operator may use (or incorporate by reference)
existing material and reports
SLIDE 8
Customization via Appendices
Appendix A – Knowledge of Facilities
Appendix B – Threat Identification
Appendix C – Evaluation & Ranking of Risk
Appendix D – Measures to Address Risk
Appendix E – Performance Measures,
Monitoring Results, Evaluating Effectiveness
Appendix F – Periodic Evaluation and
Improvement
Appendix G – Reporting Results
Appendix H – Cross Reference to Subpart P
SLIDE 9
DIMP User Guide

Discussion and Instructions for
customizing each section
 Optional Plan Sections
 77 Sample Data Tables and
Forms
 A discussion of over 40
distribution threats
 Risk Identification approaches
 3 Risk Assessment & Ranking
approaches
 Mitigation strategies
 Baseline and ongoing
performance measures
SLIDE 10
DIMP User Guide
Optional Sections for:
• Company Roles & Responsibilities
• Personnel Qualifications
• Knowledge Capture – Subject Matter Experts
• Program Effectiveness for Damage Prevention
Program, Public Awareness, QA/QC
• Exception Process
SLIDE 11
Gas Distribution Integrity Management
Plan Elements inlcude:
• Knowledge
• Indentify Threats
• Evaluate and Rank Risks
• Identify and Implement Measures to Reduce Risks
• Measure Performance, Monitor Results, Evaluate
Effectiveness
• Periodic Evaluation and Improvement
• Report Results
SLIDE 12
§192.1007 (a) Knowledge
§192.1007 (a) Knowledge. An operator must demonstrate an
understanding of its gas distribution system developed from
reasonably available information.
Demonstrated
Understanding
Data
Leak Frequency
Leaks per Mile per Year
0.80
0.70
Leaks per Mile per Year
0.60
Other
Inappropriate Operation
0.50
Equipment Malfunction
0.40
Material Failure
Other Outside Force
0.30
Excavation Damage
Natural Forces
0.20
Corrosion
0.10
0.00
System-wide
SLIDE 13
County
Map B7
§192.1007 (b) Sources of Data
§192.1007 (b) … Sources of data may include, but are not
limited to, incident and leak history, corrosion control
records, continuing surveillance records, patrolling
records, maintenance history, and excavation damage
experience.
SLIDE 14
ID Key Data Sources
Record
Geographic Information
System (GIS) database
Gas Leak Repair
Records / Database
Gas Leak Repair
Database
DOT/PHMSA Incident
Reports
Other Incident Reports
Requests to Locate Gas
Facilities
Dig-in Root Cause
Main/Service Condition
Reports
SLIDE 15
Record Type –
Database,
Electronic Record,
Paper Record
Applicable
Standard,
Policy, or
Guideline
Extent of
Missing
Records
Location of
Records
§192.1007 (a) Knowledge
§192.1007 (a) (3) Identify additional information needed
and provide a plan for gaining that information over time
through normal activities conducted on the pipeline (for
example, design, construction, operations or
maintenance activities).
Identify Data
Gaps and
Document
SLIDE 16
Documented
Action Plan
§192.1007 (a) Knowledge
§192.1007 (a) (1) Identify the characteristics of the
pipeline’s design and operations and the environmental
factors that are necessary to assess the applicable
threats and risks to its gas distribution pipeline.
§192.1007 (a) (2) Consider the information gained from
past design, operations, and maintenance.
SLIDE 17
§192.1007 (a) Knowledge
Incorporate existing reports by reference.
SLIDE 18
§192.1007 (a) Knowledge
Operators may also wish to consider:
• System Design by Material, Diameter, Operating Pressure
• Historical Construction and Leak Repair Practices
• Cathodic Protection Design & History
• Key Equipment in Use: Regulators, Mechanical Fittings, etc.
• Leak Repair frequency per mile and trend over time
• Material Failure Report Trends
• Excavation damage trends by root cause
• Reportable Gas Incidents
• Seismic Areas
• Flood Zones
• Landslide prone areas
SLIDE 19
History of Material Types and Years
Installed
Mains
Services
Material Type
Current Miles
of Main
Cast Iron
Wrought Iron
Bare Steel – with CP
Bare Steel – No CP
Coated Steel – with CP
Coated Steel – no CP
Ductile Iron
Copper
Plastic - PVC
Plastic - ABS
Plastic – Century MDPE 2306
Plastic – Aldyl-A
Plastic – HDPE 3306
Plastic – All Others
SLIDE 20
Years Installed
(of remaining)
Number of
Services
Years
Installed (of
remaining)
Historical Construction Practices
Construction Practice/Method
Replacement via insertion of Copper
Replacement via Insertion of Plastic
Replacement via insertion and pipe
bursting/splitting
Internal lining / slip-lining
Joint Trench with other utilities
Unguided Bore – soil displacement/Ram
Guided Directional Bore / Drill
Blasting
Plow-in
SLIDE 21
Year first
deployed
Year Ceased
Leak Repair Frequency Rates
SLIDE 22
§192.1007 (a) Knowledge
Role of Subject Matter Experts
• Documentation
• Selection and Qualifications
Demonstrated
Understanding
May also wish to involve SMEs in:
•Threat Identification
•Evaluation & Risk Ranking
SLIDE 23
§192.1007 (b) Identify Threats
§192.1007 (b) An operator must consider reasonably
available information to identify existing and potential
threats.
SLIDE 24
SME Involvement in Threat Identification
Sub-Threat
Material ABS – Acrylonitrile Butadiene Styrene
or Weld
Failure
SME’s to Consider the
following
Is ABS pipe known to
exist in the system?
Is there a history of
leakage of ABS pipe due
to material failure?
CAB – Cellulose Acetate Butyrate
Is CAB pipe known to
exist in the system?
Is there a history of
leakage of CAB pipe
due to material failure?
SLIDE 25
Threat Applicable?
SME –
Yes / No
Corrosion Threats
• Cast Iron Graphitization
• Ductile Iron
• Bare Steel
• Copper Pipe/Services
• Coated Steel Pipe w/o CP
• Damage by Stray Current
• Internal Corrosion
• Atmospheric Corrosion
• Pipe installed in Casing
SLIDE 26
Natural Forces
• Seismic Activity
• Earth Movement /
Landslide
• Frost Heave
• Tree Root Damage
• Floods
• Snow / Ice Damage
• Other – Wild Fire,
Lightning
SLIDE 27
Excavation Damage
…… The largest threat
SLIDE 28
Excavation Damage
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Mis-marked facilities
Late Locates
Incorrect info from one-call center
No Call for Locate
Improper Excavation Procedures
Incorrect Facility Records
• Adequacy of Damage Prevention
Program?
SLIDE 29
Other Outside Force
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SLIDE 30
Vehicle Damage
Vandalism
Fire or Explosion
Previous Damage
Material or Weld Failure
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SLIDE 31
Early generation Plastics: PVC, ABS, CAB, PB
Century Products MDPE 2306
Aldyl-A and HDPE 3306
Delrin Insert Tap Tees
Plexco Service Tee Celcon Caps
PE Fusion Failure
Compression Couplings
Pre-1940 Oxy-Acetylene Girth Welds
Plastic Pipe Alphabet Soup:
PVC – Polyvinyl Chloride
PE – Polyethylene
ABS – Acrylonitrile Butadiene Styrene
CAB – Cellulose Acetate Butyrate
PB – Polybutylene
PP – Polypropylene
PA – Polyamide
PEX – Cross-linked Polyethylene
SLIDE 32
Fusion Failures
SLIDE 33
Mechanical Fittings
Nut-Follower
Stab
Other - Hydraulic
SLIDE 34
Bolted
Equipment Malfunction
• Valves
• Service Regulators
• Regulator/Control Station
SLIDE 35
Incorrect Operation
• Human Error / Operating Error
• Failure to Follow Authorized Procedures
– Unauthorized Installation or Repair Methods
– Service Lines bored thru sewers
SLIDE 36
Other
• Bell Joint Leakage
• Copper Sulfide
• Construction over gas mains & services
SLIDE 37
§192.1007 (b) Identify Threats
§192.1007 (b) An operator must consider reasonably
available information to identify existing and
potential threats. Sources of data may include,
but are not limited to, incident and leak history,
corrosion control records, continuing surveillance
records, patrolling records, maintenance history, and
excavation damage experience.
SLIDE 38
Threat Identification –
PHMSA Advisory Bulletins
Year
PHMSA
Bulletin
Number
Summary
Recent events on natural gas distribution system facilities appear to
73 FR Dangers of Abnormal be related to either the stress of snow and ice or malfunction of
12796 - Snow and Ice Build- pressure control equipment due to ice blockage of pressure control
2008
ADB-08- up on Gas Distribution equipment vents by ice. This advisory bulletin advises owners and
03
Systems
operators of gas pipelines of the need to take steps to prevent
damage to pipeline facilities from accumulated snow or ice.
73 FR
11695 2008
ADB-0802
Subject
Issues Related to
Mechanical Couplings
Used in Natural Gas
Distribution Systems
Updated Notification
72 FR
of the Susceptibility to
51301 2007
Premature Brittle-like
ADB-07Cracking of Older
02
Plastic Pipe
SLIDE 39
This notice updates information provided in Advisory Bulletin
ADB–86–02 and advises owners and operators of gas pipelines to
consider the potential failure modes for mechanical couplings used
for joining and pressure sealing two pipes together.
PHMSA is issuing this updated advisory bulletin to owners and
operators of natural gas pipeline distribution systems concerning
the susceptibility of older plastic pipe to premature brittle-like
cracking.
Threat Identification –
NTSB Recommendations &
Letters
NTSB
Recommendation
Year Report
Number
Number
1991
P96-016
1991
P92-001
1990
PAR-9201
Report Type
Safety
Recommendation
Safety
Recommendation
Accident Report
Deaths Injuries
2
3
third party, failed PE
coupling
0
0
regulator failure
2
24
operating error
1990
P91-012
Safety
Recommendation
1
9
1989
P89-001
Safety
Recommendation
2
0
Accident Report
0
4
1988
SLIDE 40
PAR-8901
Root Cause(s)
ground movement
caused by leaking
water main, cast iron
graphitization
mechanical coupling
failure
operating error
§192.1007 (c) Evaluate and Rank Risk
§192.1007 (c) Evaluate and rank risk. An operator must
evaluate the risks associated with its distribution
pipeline. In this evaluation, the operator must
determine the relative importance of each threat and
estimate and rank the risks posed to its pipeline.
This evaluation must consider each applicable
current and potential threat, the likelihood of failure
associated with each threat, and the potential
consequences of such a failure.
SLIDE 41
Evaluation & Ranking Risk
Possible Methodologies
• Data Centric Risk Evaluation and Ranking
Methodology
• Subject Matter Expert (SME) Risk Evaluation
and Ranking Methodology
• Blended Risk Evaluation and Ranking
Methodology
SLIDE 42
Evaluation & Ranking Risk
Risk Evaluation by Geographical Regions
• Begin with the End in Mind – Targeting Mitigation
• Data availability may be the leading factor
• Going too small may result in poor results
• Going too large may not yield the ability to target
mitigation
SLIDE 43
Data Centric Risk
Evaluation
Consequence of
Failure
Risk
Frequency of
Failure
SLIDE 44
Data Centric Risk
Evaluation
Corrosion
Natural Forces
Excavation
Frequency of
Failure
Outside Force
Leaks/Incidents per
mile per year
Material/Weld/
Joint
Equipment
Incorrect
Operation
SLIDE 45
Frequency of Failure
Use of Historical Leak Repair and Incident History
•Uses data the operator already collects
•Provides data on root cause
•Outcome easy to validate based on actual experience
•Confidence when using to target mitigation
Projected Leak Frequency - Bare Steel Mains
Corrosion Leaks per Mile of Bare Steel per Year
(FOF Level 1 - Mains)
0.7
Leaks / mile / year
0.6
0.5
0.4
0.3
0.2
0.1
0
A1
B4
C3
B3
C2
A4
B1
Region
SLIDE 46
A3
A2
B2
C4
C1
Data Centric Risk
Evaluation
Population Density
Leak Severity
Consequence of
Failure
Release Volume
Leak Migration
SLIDE 47
Implementation of the NGA/SGA
DIMP Model – A Case Study
Wednesday 9:15 AM – 10:00 AM
Rob McElroy – New Century Software
(Palm Ballroom)
SLIDE 48
SME Risk Evaluation
• An approach for those who lack Data
• Risk Scores developed from both likelihood
and consequence
Primary
Threat
Other
Outside
Force
Damage
SLIDE 49
Relative
Freq of
FOF
Failure
Score
Sub(FOF)
Selected by
Threat
Score
FOF Score general descriptor
SME(s)
Vehicle
0
No history of damage to meters or risers
Damage
1
Leaks or damage are infrequent, active
to Riser /
program in place to relocate at-risk
Meter
meters/risers
2
Leaks or damage are moderate in
number, damaged meters/risers are
relocated as appropriate
3
Frequent leaks or damage, mitigation
not in place or not effective
SME
Comment(s)
§192.1007 (d) Identify and Implement
Measures to address risks
§192.1007 (d) Identify and implement measures to
address risks. Determine and implement measures
designed to reduce the risks from failure of its gas
distribution pipeline. These measures must include
an effective leak management program (unless all
leaks are repaired when found).
SLIDE 50
Validation of Leak Management
Program Effectiveness
Reference to Requirement
Established in the Standard or
Procedure
Program Element
Qualification/Training requirements for personnel conducting leak
survey
Auditing and Quality Assurance of Leak Survey Equipment
Criteria for leak severity classification
Established Frequency of Leak Survey in Business Districts, at intervals
not exceeding 15 months, but at least once each calendar year.
Established Frequency of Leak Survey for Cathodically UnprotectedKey Performance Metric
% of Leak Survey Completed
Lines subject to §192.465(e) on which electrical surveys for corrosion
are impractical, at least once every 3 calendar years at intervals not within the time allowed by
Standard
exceeding 39 months.
% of Leaks Eliminated or
Established Frequency of Leak Survey of Remaining Lines at least once
Repaired within the time
every 5 calendar years at intervals not exceeding 63 months.
allowed by Standard /
Hazardous Leaks Requiring Immediate Repair – Ongoing action
required
Procedure
Non-hazardous Leaks Requiring Scheduled Repair – Time limit is % of Leak Survey Devices
audited that fully comply with
established to Eliminate Leak
calibration and maintenance
Non-Hazardous Leak NOT requiring scheduled repair– Monitoring
requirements
Requirements established
Records and Data Management procedures defined
Performance Metrics established
SLIDE 51
2010
2011
2012
Report Results
•Excess Flow Valves Installed
•Number of hazardous leaks either eliminated or repaired,
categorized by cause
•Number of excavation damages*
•Number of excavation tickets
•Total number of leaks either eliminated or repaired,
categorized by cause
•Information related to failure of compression couplings,
excluding those that result only in nonhazardous leaks
(effective Jan 1, 2011)
SLIDE 52
Number of Excavation Damages*
SLIDE 53
New Gas Distribution Annual Report Form
June 28, 2010 Federal Register
SLIDE 54
Questions??
ekirkpatrick@structint.com
SLIDE 55