{"operation":"document","citation":"PHMSA Guidance, DIMP Enforcement Guidance","title":"DIMP Enforcement Guidance","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-12-07","effective_on":"2015-12-07","summary":"DIMP Enforcement Guidance Document DIMP_Enforcement_Guidance_12_7_2015.pdf (686.32 KB) Distribution Integrity Management Plan (DIMP) Enforcement Guidance. The materials contained in this document consist of guidance, techniques, procedures and other information for internal use by the PHMSA pipeline safety enforcement staff. This guidance document describes the practices used by PHMSA pipeline safety investigators an","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-dimp-enforcement-guidance-a127db96.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-dimp-enforcement-guidance-a127db96.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-dimp-enforcement-guidance-a127db96","source_url":"https://www.phmsa.dot.gov/pipeline/enforcement/dimp-enforcement-guidance","body":"DIMP Enforcement Guidance\n\nDocument\n\n DIMP_Enforcement_Guidance_12_7_2015.pdf (686.32 KB)\n\n        Distribution Integrity Management Plan (DIMP) Enforcement Guidance. The materials contained in this document consist of guidance, techniques, procedures and other information for internal use by the PHMSA pipeline safety enforcement staff. This guidance document describes the practices used by PHMSA pipeline safety investigators and other enforcement personnel in undertaking their compliance, inspection, and enforcement activities.\n\n          Issued Date: Monday, December 7, 2015\n\n<<<PAGE 1>>>\n\nGas Distribution Pipeline Integrity Management Enforcement\nGuidance\n49 CFR Part 192 – Subpart P\nIntroduction\nThe materials contained in this document consist of guidance, techniques, procedures and other information\nfor internal use by the PHMSA pipeline safety enforcement staff. This guidance document describes the\npractices used by PHMSA pipeline safety investigators and other enforcement personnel in undertaking their\ncompliance, inspection, and enforcement activities. This document is U.S. Government property and is\nto be used in conjunction with official duties.\nThe Federal pipeline safety regulations (49 CFR Parts 190-199) discussed in this guidance document\ncontains legally binding requirements. This document is not a regulation and creates no new legal\nobligations. The regulation is controlling. The materials in this document are explanatory in nature and reflect\nPHMSA’s current application of the regulations in effect at the time of the issuance of the guidance. In\npreparing an enforcement action alleging a probable violation, an allegation must always be based on the\nfailure to take a required action (or taking a prohibited action) that is set forth directly in the language of the\nregulation. An allegation should never be drafted in a manner that says the operator “violated the guidance.”\nNothing in this guidance document is intended to diminish or otherwise affect the authority of PHMSA to carry\nout its statutory, regulatory or other official functions or to commit PHMSA to taking any action that is subject\nto its discretion. Nothing in this document is intended to and does not create any legal or equitable right or\nbenefit, substantive or procedural, enforceable at law by any person or organization against PHMSA, its\npersonnel, State agencies or officers carrying out programs authorized under Federal law.\nDecisions about specific investigations and enforcement cases are made according to the specific facts\nand circumstances at hand. Investigations and compliance determinations often require careful legal and\ntechnical analysis of complicated issues. Although this guidance document serves as a reference for the\nstaff responsible for investigations and enforcement, no set of procedures or policies can replace the need for\nactive and ongoing consultation with supervisors, colleagues, and the Office of Chief Counsel in enforcement\nmatters.\nComments and suggestions for future changes and additions to this guidance document are invited and\nshould be forwarded to your supervisor.\nThe materials in this guidance document may be modified or revoked without prior notice by PHMSA\nmanagement.\n\n<<<PAGE 2>>>\n\nTable of Contents\nGlossary ........................................................................................................................................................................ 2\n§192.1001 What definitions apply to this subpart? ....................................................................................................... 3\n§192.1003 What do the regulations in this subpart cover? ............................................................................................ 5\n§192.1005 What must a gas distribution operator (other than a master meter or small LPG operator) do\nto implement this part? ............................................................................................................................... 7\n§192.1007 What are the required elements of an integrity management plan?\n192.1007(a) Knowledge ..............................................................................................................................10\n192.1007(b) Identify threat .........................................................................................................................15\n192.1007(c) Evaluate and rank risk ...........................................................................................................21\n192.1007(d) Identify and implement measures to address risks .................................................................26\n192.1007 (e) Measure performance, monitor results, and evaluate effectiveness ......................................31\n192.1007(f) Periodic Evaluation and Improvement ...................................................................................35\n192.1007(g) Report results .........................................................................................................................38\n§192.1009, §191.12 What must an operator report when a mechanical fitting fails? ................................................... 41\n§192.1011 What records must an operator keep? ............................................................................................................. 43\n§192.1013 When may an operator deviate from required periodic inspections under this part? .................................. 46\n§192.1015 What must a master meter or small liquefied petroleum gas (LPG) operator do to implement this subpart?\n192.1015(a) General ................................................................................................................................... 48\n§192.1015(b) What are the required elements of an integrity management plan?\n192.1015(b)(1) Knowledge ...........................................................................................................................51\n192.1015(b)(2) Identify threats.....................................................................................................................55\n192.1015(b)(3) Rank risks ............................................................................................................................60\n192.1015(b)(4) Identify and implement measures to mitigate risks ..............................................................64\n192.1015(b)(5) Measure performance, monitor results, and evaluate effectiveness.....................................68\n192.1015(b)(6) Periodic Evaluation and Improvement ................................................................................70\n§192.1015(c) What are the required elements of an integrity management plan? (c) Records ..................................... 73\nPage 1\n\n<<<PAGE 3>>>\n\nFor a complete “Glossary of Terms” please refer to the following link:\nhttp://www.phmsa.dot.gov/staticfiles/PHMSA/Pipeline/TQGlossary/Glossary.html\nPage 2\n\n<<<PAGE 4>>>\n\nEnforcement\nGuidance\nRevision Date Code Section Section Title Existing Code\nLanguage\nOrigin of Code Last Amendment Interpretation\nSummaries\nAdvisory\nBulletin/Alert\nNotice\nSummaries\nDistribution Integrity Management\nPart 192\n12/7/2015\n§192.1001\nWhat definitions apply to this subpart?\nThe following definitions apply to this subpart:\nExcavation Damage means any impact that results in the need to repair or\nreplace an underground facility due to a weakening, or the partial or complete\ndestruction, of the facility, including, but not limited to, the protective coating,\nlateral support, cathodic protection or the housing for the line device or facility.\nHazardous Leak means a leak that represents an existing or probable hazard to\npersons or property and requires immediate repair or continuous action until the\nconditions are no longer hazardous.\nIntegrity Management Plan or IM Plan means a written explanation of the\nmechanisms or procedures the operator will use to implement its integrity\nmanagement program and to ensure compliance with this subpart.\nIntegrity Management Program or IM Program means an overall approach by\nan operator to ensure the integrity of its gas distribution system.\nMechanical fitting means a mechanical device used to connect sections of pipe.\nThe term “Mechanical fitting” applies only to:\n(1) Stab Type fittings;\n(2) Nut Follower Type fittings;\n(3) Bolted Type fittings; or\n(4) Other Compression Type fittings.\nSmall LPG Operator means an operator of a liquefied petroleum gas (LPG)\ndistribution pipeline that serves fewer than 100 customers from a single source.\n192-113, 74 FR 63906, Dec. 4, 2009\n192-116, 76 FR 5494, February 1, 2011\nPage 3\n\n<<<PAGE 5>>>\n\nOther Reference\nMaterial\n& Source\nGuidance\nInformation\n1. A line does not have to experience a leak or release to be considered to have\nbeen damaged by excavation damage.\n2. An operator need not classify leaks as hazardous or non-hazardous provided it\nrepairs all leaks when found. To qualify for this exclusion, an operator must\ntreat all leaks as if they were hazardous, providing for immediate repair or\ncontinuous action until the leak is repaired.\nExamples of a\nProbable\nViolation or\n1. Operator does not have a comprehensive list of definitions.\n2. Operator does not include all definitions in their Distribution Integrity\nManagement Plan (DIMP) or other plans.\n3. Operator definitions are not consistent with Part 192.\nInadequate\nProcedures\nDepending on the circumstances, some of the examples listed in this section may be\ninadequate plans and procedures, and not probable violations. Thus, the enforcement\ntool to address these issues would be a Notice of Amendment and not a Notice of\nProbable Violation or a Warning Letter. Section 3 of the Enforcement Procedures\nprovides guidance on selecting the appropriate enforcement action.\nExamples of\nEvidence\n1. Copy of written Distribution Integrity Management Plan (DIMP) or applicable\nportions that depict an omission or deficiency in the plan.\n2. Operator records.\nOther Special\nNotations\nPage 4\n\n<<<PAGE 6>>>\n\nEnforcement\nGuidance\nRevision Date Code Section Section Title Existing Code\nLanguage\nOrigin of Code Last Amendment\nInterpretation\nSummaries\nAdvisory\nBulletin/Alert\nNotice\nSummaries\nOther Reference\nMaterial\n& Source\nGuidance\nInformation\nDistribution Integrity Management\nPart 192\n12/7/2015\n§192.1003\nWhat do the regulations in this subpart cover?\nGeneral. This subpart prescribes minimum requirements for an IM program for any\ngas distribution pipeline covered under this part, including liquefied petroleum gas\nsystems. A gas distribution operator, other than a master meter operator or a small\nLPG operator, must follow the requirements in Sec. §192.1005-192.1013 of this\nsubpart. A master meter operator or small LPG operator of a gas distribution\npipeline must follow the requirements in §192.1015 of this subpart.\n192-113, 74 FR 63906, Dec. 4, 2009\nInterpretation: PI-11-0016 Date: 09-12-2012 – Response to Atmos Energy;\nSeptember 12, 2012 and DIMP FAQ C.3.7 asserting PHMSA’s position that farm\ntaps have been historically considered service lines, a subset of distribution pipelines\nand are thus subject to all distribution line requirements.\nInterpretation: PI-11-0008 Date: 04-19-2011 - Response to Northern Natural\nGas Company; Apr 19, 2011 and DIMP FAQ C.3.7 explained that - operators of\ndistribution, gathering, and transmission lines whose system includes “farm taps”\nmeeting the definition of a distribution line must have a DIMP covering these\nfacilities.\nDistribution Integrity Management FAQs\n• C.2.1 Must peak shaving and LNG facilities connected to our distribution\npipeline system be considered in our DIMP?\n1. The DIMP must address all gas distribution systems covered by this part\nincluding systems in which the operator transports natural gas, liquefied\npetroleum gas (LPG), landfill gas (LFG), liquefied natural gas (LNG), and\npropane-air mixtures.\n2. All distribution pipeline and appurtenances are subject to DIMP including\nmains, valves, fittings, regulator stations, drips, service lines, risers, service\nmeter and regulator sets, farm taps, high pressure distribution systems and low\npressure distribution systems.\n3. Operators must follow their procedures. The DIMP and any individual\nprocedures documents must include management approvals, origin date, and\nthe effective date of the last revision. For additional information, see the\nguidance section of §192.1005.\nPage 5\n\n<<<PAGE 7>>>\n\nExamples of a\nProbable\nViolation or\nInadequate\nProcedures\nExamples of\nEvidence\nOther Special\nNotations\n4. Master Meter and Small LPG operators are treated differently in the DIMP\nRule than larger operators. For Master Meter and Small LPG operators, the\nintegrity management program must include the appropriate set of\nmechanisms or procedures to develop and implement each program element.\nThe operator may employ a written explanation of the process employed\n(mechanism) to develop and implement a required element that is less specific\nthan a written procedure. The IM program for these pipelines should reflect the\nrelative simplicity of these types of pipelines. The DIMP could be concise,\nbut still must be sufficient for operator personnel to understand and implement\nthe program on a consistent basis.\n1. The operator’s DIMP does not include all of the operator’s distribution\npipeline facilities.\n2. The operator does not address LPG or other types of gas transported when\napplicable.\n3. Necessary regulated pipeline systems are not covered by a DIMP.\n4. The DIMP does not include all pipe and appurtenances.\nDepending on the circumstances, some of the examples listed in this section may be\ninadequate plans and procedures, and not probable violations. Thus, the enforcement tool\nto address these issues would be a Notice of Amendment and not a Notice of Probable\nViolation or a Warning Letter. Section 3 of the Enforcement Procedures provides guidance\non selecting the appropriate enforcement action.\n1. Copy of written DIMP or applicable portion that shows omission or deficiency\nin the DIMP.\n2. Copies of the applicable pages of the DIMP showing that the operator has not\nclearly stated other types of gas are transported.\n3. Operator records.\n4. Documented photographic evidence demonstrating the violation.\n5. Documented oral and/or written statements from operator personnel.\nPage 6\n\n<<<PAGE 8>>>\n\nEnforcement\nGuidance\nRevision Date Code Section Section Title Existing Code\nLanguage\nOrigin of Code Last Amendment\nInterpretation\nSummaries\nAdvisory\nBulletin/Alert\nNotice\nSummaries\nOther Reference\nMaterial\n& Source\nDistribution Integrity Management\nPart 192\n12/7/2015\n§192.1005\nWhat must a gas distribution operator (other than a master meter or small LPG\noperator) do to implement this subpart?\nNo later than August 2, 2011 a gas distribution operator must develop and\nimplement an integrity management program that includes a written integrity\nmanagement plan as specified in §192.1007.\n192-113, 74 FR 63906, Dec. 4, 2009\nAddressed in DIMP Final Rule preamble in Federal Register / Vol. 74, No. 232 /\nFriday, December 4, 2009 / Rules and Regulations at:\n• Comment Topic 4: Implementation time. Page 63909\n• Comment Topic 11: Required documentation. Page 63915\nDistribution Integrity Management FAQs\n• C.3.1 If an operator has both natural gas and LPG systems, must it have\ntwo separate DIMP plans or may it have a single plan?\n• C.3.2 Must an operator have one DIMP plan covering all of its systems or\ncould it have separate plans for different systems or service areas?\n• C.3.3 Will companies operating in several states need to develop\nindividual DIMP plans for each state?\n• C.3.4 What is the relationship between an operations & maintenance\nmanual and a DIMP plan?\n• C.3.6 How does the new DIMP rule impact operators of gas piping\nsystems on military bases, Federal Government, or Indian Tribal\nGovernment land?\n• C.3.7 Are operators required to include “farm taps” in their distribution\nintegrity management plan?\n• C.3.8 What do operators need to have implemented by August 2, 2011?\n• C.3.10 What are the requirements for distribution systems put in service\nafter 8/2/2011?\n• C.3.11 What are the requirements for distribution systems acquired after\n8/2/2011?\nPage 7\n\n<<<PAGE 9>>>\n\nGas Piping Technology Committee (GPTC) Guide Material Appendix G-192-8\n• Section 1 - Introduction 1.1-1.3\n• Section 2 - Elements of a Distribution Integrity Management Plan 2.1-2.2\n• Section 10 - Sample DIMP Approaches 10.1-10.2\nGas Distribution Integrity Management Program: Resources\n• DIMP Inspection Forms\n• Technical Reports\n• Distribution Integrity Management: Guidance for Master Meter and Small\nLiquefied Petroleum Gas Pipeline Operators\n• Plastic Piping Data Collection Initiative\n• Gas Piping Technology Committee (GPTC) Guide Material Appendix\nG-192-8 Distribution Management Integrity Program\n• SHRIMP - Simple Handy Rule based Integrity Management Plan\n• Industry Associations\n• Excavation Damage Prevention Organizations\nGuidance\nInformation\n1. From 192.1001: Integrity Management Plan or IM Plan “\nmeans a written\nexplanation of the mechanisms or procedures the operator will use to\nimplement its integrity management program and to ensure compliance with\nthis subpart.” An operator must have a written distribution integrity\nmanagement plan (DIMP) that contains or references procedures for\ndeveloping and implementing each required element in §192.1007.\n2. The procedures must have adequate detail to clearly describe the manner in\nwhich each requirement will be met.\n3. The procedure must be documented so an inspector can make a reasonable\ndetermination as to the accuracy and thoroughness of the procedure. The\nprocedures need to provide a description of who, what, when, where, and how\nthe operator will perform the elements. The DIMP can be concise, but still\nmust be sufficient for operator personnel to understand and implement the\nprogram on a consistent basis. Operators must follow their procedures.\n4. The DIMP and any individual procedures’ documents should include\nmanagement approvals, origin date, and the effective date of the last revision.\n5. From §192.1007, Integrity Management Program or IM Program “means an\noverall approach by an operator to ensure the integrity of its gas distribution\nsystem.” The operator’s integrity management program must include the\nappropriate set of procedures to develop and implement each program element\nas required in 192.1007.\n6. An operator’s DIMP may vary in length and complexity depending on the\nspecific equipment in service, the variety of facilities, the locations, and\nreferenced versus incorporated material.\n7. The structure of the DIMP is not prescribed and may consist of a single\ncomprehensive DIMP or multiple cross-reference volumes with referenced\ndocuments. The DIMP can be made available to personnel as hard-copy or\ncomputer based documents but must be accessible at locations where DIMP\nrequired activities are conducted. If the DIMP is computer based, the operator\nmust provide a means to access the procedures in the event of computer\nfailure.\nPage 8\n\n<<<PAGE 10>>>\n\nExamples of a\nProbable\nViolation or\nInadequate\nProcedures\nExamples of\nEvidence\nOther Special\nNotations\n8. Purchased or off-the-shelf plans and procedures must be fully customized to\nthe operator to cover their specific operating requirements, and the procedures\nmust have adequate detail to clearly describe the manner in which each\nrequirement will be met.\nGuidance specific to an operator who transfers pipeline assets to another\noperator but retains responsibility, by contract, for maintenance and distribution\nintegrity management activities.\n1. Which operator is accountable for implementing the DIMP?\nOPS and the States inspect operators for compliance with the pipeline safety\nregulations. An ‘operator’ is defined in 49 C.F.R. §192.3 as “a person who\nengages in the transportation of gas”. A ‘person’ is further defined as an\nindividual or firm, joint venture, partnership, corporation, association, State,\nmunicipality, cooperative association, or joint stock association, and including\nany trustee, receiver, assignee, or personal representative thereof. If an\noperator retains responsibility for operations and maintenance responsibilities\nincluding DIMP activities, that operator is responsible for complying with the\npipeline safety regulations.\n1. The operator does not have a DIMP written and implemented by August 2,\n2011.\n2. The DIMP does not contain the necessary procedures to demonstrate that the\nDIMP was written and is being implemented.\n3. A new system was put into operation and service without a written DIMP.\n4. An operator who acquired an existing system and did not continue operations\nunder the existing DIMP or did not incorporate the acquired assets into its\nDIMP.\nDepending on the circumstances, some of the examples listed in this section may be\ninadequate plans and procedures, and not probable violations. Thus, the enforcement\ntool to address these issues would be a Notice of Amendment and not a Notice of\nProbable Violation or a Warning Letter. Section 3 of the Enforcement Procedures\nprovides guidance on selecting the appropriate enforcement action.\n1. Copies of the applicable pages of the DIMP showing that the operator has not\nclearly stated that the DIMP was written and implemented by August 2, 2011.\n2. Documented oral and/or written statements from operator personnel.\nPage 9\n\n<<<PAGE 11>>>\n\nEnforcement\nGuidance\nRevision Date Code Section Section Title Existing Code\nLanguage\nOrigin of Code Last Amendment Interpretation\nSummaries\nAdvisory\nBulletin/Alert\nNotice\nSummaries\nDistribution Integrity Management\nPart 192\n12/7/2015\n§192.1007(a)\nWhat are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing\nand implementing the following elements:\n(a) Knowledge. An operator must demonstrate an understanding of its gas\ndistribution system developed from reasonably available information.\n(1) Identify the characteristics of the pipeline's design and operations and the\nenvironmental factors that are necessary to assess the applicable threats and risks to\nits gas distribution pipeline.\n(2) Consider the information gained from past design, operations, and\nmaintenance.\n(3) Identify additional information needed and provide a plan for gaining that\ninformation over time through normal activities conducted on the pipeline (for\nexample, design, construction, operations or maintenance activities).\n(4) Develop and implement a process by which the IM program will be reviewed\nperiodically and refined and improved as needed.\n(5) Provide for the capture and retention of data on any new pipeline installed.\nThe data must include, at a minimum, the location where the new pipeline is\ninstalled and the material of which it is constructed.\n192-113, 74 FR 63906, Dec. 4, 2009\n192-116, 76 FR 5494, Feb 1, 2011\nAdvisory Bulletin ADB-12-06 - Issued May 7, 2012\nPHMSA is issuing an Advisory Bulletin to remind operators of gas and hazardous\nliquid pipeline facilities to verify their records relating to operating specifications for\nmaximum allowable operating pressure (MAOP) required by 49 CFR 192.517 and\nmaximum operating pressure (MOP) required by 49 CFR 195.310.\nAdvisory Bulletin ADB-12-05 – Issued March 23, 2012\nPHMSA urges owners and operators to conduct a comprehensive review of their\ncast iron distribution pipeline systems and replacement programs and to accelerate\npipeline repair, rehabilitation, and replacement of aging and high-risk pipe. In\naddition ADB notes regulation requirement for natural gas distribution companies to\ndevelop DIMP for pipelines owned, operated or maintained.\nPage 10\n\n<<<PAGE 12>>>\n\nAdvisory Bulletin ADB-11-01 – Issued January 10, 2011\nPHMSA-2010-0381; Pipeline Safety: Establishing Maximum Allowable Operating\nPressure or Maximum Operating Pressure Using Record Evidence, and Integrity\nManagement Risk Identification, Assessment, Prevention, and Mitigation.\nAdvisory Bulletin ADB-09-02 Issued September 30, 2009\nPotential for issues with Weldable Compression Coupling Installation.\nOther Reference\nMaterial\n& Source\nAddressed in DIMP Final Rule preamble in Federal Register / Vol. 74, No. 232 /\nFriday, December 4, 2009 / Rules and Regulations at:\n• Comment Topic 20: Knowledge of pipeline. a. Environmental factors, Page\n63919\nDistribution Integrity Management FAQs\n• C.4.2 Can the DIMP plan incorporate by reference the operator’s procedures\nfrom their other manuals or plans?\n• C.4.a.1 The rule requires that an operator know its system. Must an operator\nexcavate simply to gather information about parts of its system where it may\nnot now have complete knowledge?\n• C.4.a.2 There are some characteristics about an operator’s system that may\nnot be known during the development of the IM plan. What are PHMSA’s\nexpectations for filling those voids?\n• C.4.a.3 Who qualifies as a “subject matter expert”?\n• C.4.a.4 What data will be required to be collected for new gas pipelines\ngoing in the ground?\n• C.4.a.5 What comprises \"reasonably available\" information?\n• C.4.a.6 Must an operator’s plan include the sources used to demonstrate an\nunderstanding of its gas distribution system?\nGas Piping Technology Committee (GPTC) Guide Material Appendix G-192-8\n• Section 3 Knowledge\nGPTC provides a useful list of records from which information is gathered. In\naddition to the information from the GPTC DIMP Appendix, the GPTC Guide\nMaterial Appendix G-192-17 contains a list of explicit requirements for reports,\ninspections, tests, written procedures, records and similar actions.\nPage 11\n\n<<<PAGE 13>>>\n\nGuidance\nInformation\n1. The operator must have a written distribution integrity management plan\n(DIMP) that contains procedures for developing and implementing each\nrequirement of §192.1007(a). The procedures must have adequate detail to\nclearly describe the manner in which each requirement will be met. The\nprocedures need to provide a description of who, what, when, where, and how\nthe operator will implement the elements. Operators must follow their\nprocedures. The DIMP and any individual procedures documents should\ninclude management approvals, origin date, and the effective date of the last\nrevision. For additional information, see the guidance section of §192.1005.\n2. An operator must have knowledge of its natural gas distribution system\nincluding, but not limited to, the following characteristics: location, material\ncomposition, piping sizes, joining methods, construction methods, date of\ninstallation, soil conditions (where appropriate), operating and design\npressures, history, operating experience performance data, condition of\nsystem, and any other characteristics noted by the operator as important to\nunderstanding its system. This information may be obtained from sources\nincluding system maps, construction records, work management system(s),\ngeographic information system(s), corrosion records, and personnel who have\nknowledge of the system (Subject Matter Experts)\n3. The operator must have a list of the information sources used to develop the\nDIMP.\n4. The operator knowledge of the system should be focused on those\ncharacteristics which are needed to assess threats, evaluate risks to the system\nto identify risk reduction measures, and group facilities with like\ncharacteristics. An operator must begin by reviewing the data that\ncharacterizes its unique distribution system as the initial step in identifying\nthreats and assessing and prioritizing the threats. Characteristics evaluated by\nthe operator must allow the operator to identify facilities with known and\npotential problems. For example, operators should examine the design\ncharacteristic “joining method” to determine if their system contains\nmechanically joined pipe that could be a threat to the integrity of the system.\n5. Operators who transport gases other than natural gas need to describe in their\nDIMP how the characteristics of the gas impact the threats and risk and\ninclude the differences from natural gas.\n6. The term “environmental factors” has caused some confusion. As clarified in\nthe DIMP Final Rule in response to Comment #20, environmental factors are\n“necessary to assess the applicable threats and risk to gas distribution pipelines\nand does not refer to consequences.” 74 Fed. Reg. 63906, 63919. The term\n“environmental” as used in the rule does NOT refer to “EPA” type\nenvironmental factors such as mercury regulators, PCBs, or contaminated soils\n(which require remediation when removed). It does refer to operating\nenvironment characteristics including but not limited to population density,\nlandslide, corrosive soil, valve placement, seismic zones, flood zones, areas\nwith wall-to-wall paving, frost impacts, geologic conditions, construction\nactivities (significance of near-by construction), wash outs, types of soils, etc.\nSome of these factors will not apply to certain operators. An operator’s DIMP\nmust include information about the environmental factors reviewed but does\nnot need to describe the criteria they used to select them to develop the\nknowledge of their system.\nPage 12\n\n<<<PAGE 14>>>\n\nExamples of a\nProbable\nViolation or\nInadequate\nProcedures\n7. The operator is required to have a list of the information sources used to develop\nthe DIMP to demonstrate that they have considered all reasonably available\nrecords. All reasonably available records which provide information on a\nsignificant impact on system integrity must be included.\n8. Some historical data may be no longer applicable to the current condition of the\npipeline system. If the pipe was replaced, the data about the previous pipe may\nno longer be relevant. Such data may be relevant where the circumstances (e.g.,\nconstruction practices, coatings, backfill materials, pipe materials, environmental\nconditions) of the pipe prior to replacement exist elsewhere and are relevant to\nexisting risks in the operator’s system. For example, if bare steel pipe has been\nreplaced, but some bare steel still exists in the system, then data concerning the\nreplaced pipe may still be relevant.\n9. If an operator acquires a pipeline and the historical records were not obtained or\nare not reasonably available, the records do not need to be recreated. However,\nthis missing data must be identified as such within the operator’s DIMP, and a\nplan must be established for collection of relevant information.\n10. Operators need to consider failures without a release to identify potential\nthreats, and this type of information is considered reasonably available. For\nexample, operators may evaluate where pressure regulators froze off and\nwhere upsets in the system could have occurred.\n11. For data identified by the operator as needed for a threat identification and risk\nevaluation, there needs to be a process to identify facilities for which records are\nmissing, inaccurate, or incomplete.\n12. Collecting additional data and improving existing data is only required to occur\nas part of normal pipeline activities and over time. There must be a mechanism\nfor individuals performing normal pipeline activities to know what additional\ndata is needed.\n13. Forms, recordkeeping procedures, data management systems and/or other\nmethods used to collect information related to the physical attributes and/or\noperating and maintenance activities of distribution pipeline facilities should be\nappropriately modified to provide for the collection of reasonable available\ninformation. Personnel should be trained to properly collect and record the\nneeded information and use the required forms.\n1. The operator does not have a procedure that covers the tasks required.\n2. The operator fails to follow the written procedures.\n3. Operator did not demonstrate that they have looked at all reasonably available\nsources to find information from past design, operations, inspections, or\nmaintenance activities.\n4. Operator did not specifically list which documents were used to assemble\nknowledge of its system.\n5. Operator does not gather or use reasonably available data on the entire pipeline\nthat could be relevant to performing their threat assessment, risk evaluation or\nas needed to group like facilities.\n6. DIMP did not identify the records containing the appropriate characteristics of\nthe pipeline’s operating conditions to assess each threat category and\nsubcategory to the operator’s pipeline.\n7. DIMP did not identify the records containing the appropriate environmental\ncharacteristics to assess each threat category and subcategory to the operator’s\npipeline.\nPage 13\n\n<<<PAGE 15>>>\n\nExamples of\nEvidence\nOther Special\nNotations\n8. There is no procedure for identifying needed missing, inaccurate or incomplete\ndata.\n9. The operator has not identified missing, inaccurate or incomplete data.\n10. The operator has identified missing, inaccurate or incomplete data but does not\nhave a procedure or plan to collect the missing data and information over time.\n11. Operator failed to retain data on new pipeline installed.\nDepending on the circumstances, some of the examples listed in this section may be\ninadequate plans and procedures, and not probable violations. Thus, the enforcement\ntool to address these issues would be a Notice of Amendment and not a Notice of\nProbable Violation or a Warning Letter. Section 3 of the Enforcement Procedures\nprovides guidance on selecting the appropriate enforcement action.\n1. Copies of the applicable pages of the DIMP showing that the operator has not\nclearly stated the documents used to develop knowledge of the system.\n2. The list of documents used to develop knowledge of the system is inadequate in\nidentifying design, operating, or environmental characteristics of the pipeline\nsystem.\n3. Copies of applicable pages of the DIMP showing that the DIMP is not detailed\nenough for an inspector to make a reasonable determination as to the accuracy\nand thoroughness of the process.\n4. Documented photographic evidence demonstrating the violation.\n5. Documented oral and/or written statements from operator personnel.\nPage 14\n\n<<<PAGE 16>>>\n\nEnforcement\nGuidance\nRevision Date Code Section Section Title Existing Code\nLanguage\nOrigin of Code Last Amendment Interpretation\nSummaries\nAdvisory\nBulletin/Alert\nNotice\nSummaries\nDistribution Integrity Management\nPart 192\n12/7/2015\n§192.1007(b)\nWhat are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing\nand implementing the following elements:\n* * * * *\n(b) Identify threats. The operator must consider the following categories of\nthreats to each gas distribution pipeline: Corrosion, natural forces, excavation\ndamage, other outside force damage, material or welds, equipment failure, incorrect\noperations, and other concerns that could threaten the integrity of its pipeline. An\noperator must consider reasonably available information to identify existing and\npotential threats. Sources of data may include, but are not limited to, incident and\nleak history, corrosion control records, continuing surveillance records, patrolling\nrecords, maintenance history, and excavation damage experience.\n192-113, 74 FR 63906, Dec. 4, 2009\n192-116, 76 FR 5494, Feb 1, 2011\nAdvisory Bulletin ADB-13-04 – Issued August 22, 2013\nPHMSA advisory to alert all pipeline operators of a T.D. Williamson, Inc. (TDW)\nLeak Repair Clamp (LRC) recall issued by TDW on June 17, 2013. The recall\ncovers all TDW LRCs of any pressure class and any size. The LRCs may develop a\ndangerous leak due to a defective seal. Hazardous liquid and natural gas pipeline\noperators should verify if they have any TDW LRCs subject to the recall by\nreviewing their records and equipment for installation of these LRCs.\nAdvisory Bulletin ADB-13-03: Correction – Issued October 31, 2013\nPHMSA is issuing an Advisory Bulletin to remind owners and operators of liquefied\npetroleum gas (LPG) and utility liquefied petroleum gas (utility LP-Gas) plants that\nalthough they must follow the American National Standards Institute/National Fire\nProtection Association (ANSI/NFPA) standards 58 or 59, they must also follow\ncertain sections and requirements of Part 192.\nAdvisory Bulletin ADB-13-02 – Issued July 12, 2013\nPHMSA is issuing this advisory bulletin to all owners and operators of gas and\nhazardous liquid pipelines to communicate the potential for damage to pipeline\nfacilities caused by severe flooding. This advisory includes actions that operators\nshould consider taking to ensure the integrity of pipelines in case of flooding.\nPage 15\n\n<<<PAGE 17>>>\n\nAdvisory Bulletin ADB-12-05 – Issued March 23, 2012\nPHMSA urges owners and operators to conduct a comprehensive review of their\ncast iron distribution pipeline systems and replacement programs and to accelerate\npipeline repair, rehabilitation, and replacement of aging and high-risk pipe. In\naddition ADB notes regulation requirement for natural gas distribution companies to\ndevelop DIMP for pipelines owned, operated or maintained.\nAdvisory Bulletin ADB-12-03 – Issued March 6, 2012\nPHMSA advisory bulletin to alert operators using Driscopipe® 8000 High Density\nPolyethylene Pipe (Drisco8000) of the potential for material degradation.\nAdvisory Bulletin ADB-11-05 – Issued August 26, 2011\nPHMSA advisory to remind owners and operators of gas and hazardous liquid\npipelines of potential for damage to pipeline facilities caused by the passage of\nHurricanes.\nAdvisory Bulletin ADB-11-04 – Issued March 20, 2012\nPipeline Safety: Potential for Damage to Pipeline Facilities Caused by Flooding.\nAdvisory Bulletin ADB-11-02 – Issued February 9, 2011\nPipeline Safety: Dangers of Abnormal Snow and Ice Build-Up on Gas Distribution\nSystems.\nAdvisory Bulletin ADB-10-03 – Issued March 24, 2010 Pipeline Safety: Girth\nWeld Quality Issues Due to Improper Transitioning, Misalignment, and Welding\nPractices of Large Diameter Line Pipe.\nAdvisory Bulletin ADB-09-02 – Issued September 30, 2009\nPotential for issues with Weldable Compression Coupling Installation\nAdvisory Bulletin ADB-08-02 – Issued March 4, 2008\nIssues Related to Mechanical Couplings Used in Natural Gas Distribution Systems\nAdvisory Bulletin ADB-07-01 – Issued September 6, 2007\nUpdated Notification of the Susceptibility to Premature Brittle-like Cracking of\nOlder Plastic Pipe\nAdvisory Bulletin ADB-06-03 – Issued November 22, 2006\nNotice to Operators of Natural Gas and Hazardous Liquid Pipelines to Accurately\nLocate and Mark Underground Pipelines Before Construction-Related Excavation\nActivities Commence\nAdvisory Bulletin ADB-05-05 – Issued August 10, 2005\nInspecting and Testing Pilot-Operated Pressure Relief Valves\nAdvisory Bulletin ADB-04-01 – Issued September 29, 2004\nHazards Associated with de-watering of pipelines\nPage 16\n\n<<<PAGE 18>>>\n\nOther Reference\nMaterial\n& Source\nAdvisory Bulletin ADB-02-01 – Issued May 24, 2002\nNotice to Operators of Natural Gas and Hazardous Liquid Pipelines To Encourage\nContinued Implementation of Safe Excavation Practices\nAdvisory Bulletin ADB-97-05 – Issued November 12, 1997\nPotential Failure of Check Valves Following Remanufacturing\nAdvisory Bulletin ADB-97-03 – Issued March 4, 1997\nPotential Soil Subsidence on Pipeline Facilities\nAdvisory Bulletin ADB-95-02 – Issued August 9, 1995\nIncreased Pipeline Transportation Security Measures\nAdvisory Bulletin ADB-94-05 – Issued November 2, 1994\nPipelines Affected by Flooding\nAlert Notice ALN-92-01 – Issued January 8, 1992\nLightning-induced electrical discharge from tracer wire to plastic pipe.\nAlert Notice ALN-89-01 – Issued March 8, 1989\nUpdate: Additional findings relative to factors contributing to operational failures of\npipelines constructed by ERW prior to 1970\nAlert Notice ALN-87-01 – Issued March 13, 1987\nIncident involving the fillet welding of a full encirclement repair sleeve on a 14\"\nAPI 5LX-52 pipeline; King of Prussia, PA 10/07/86 pipeline failure","truncated":true,"body_characters":178316}