1. RAILROAD COMMISSION OF TEXAS Alan C. Mann Oversight and Safety Division September 2015

2. BASIC D.I.M.P. Getting The Ball Rolling

3. Distribution Integrity Management 49 CFR Part 192.1001-1015 (Subpart P) – Gas Distribution Integrity Management (IM) 3

4. 49 CFR 192, Subpart P 192.1007 – Required Elements a)Knowledge b)Threat Identification c)Evaluate and Rank Risk d)Identify and Implement Measures to Reduce Risk e)Measure Performance, Monitor Results, Evaluate Effectiveness f)Periodic Evaluation and Improvement. g)Report Results 4

5. 49 CFR 192, Subpart P 192.1007 (a) KNOWLEDGE: Demonstrate an understanding of your gas distribution system(s) developed from reasonably available information. Records: – (1) Characteristics of the system’s design, operations, and environmental factors. – (2) Information from past design, operations and maintenance. – (3) Identify your “unknowns” and devise a plan to gain that knowledge through normal activities. – (4) Develop and Implement a DIM Plan review/improvement process. (This becomes a record of knowledge.) – (5) Capture and retain records regarding new installations. (Location, Material-Specs, Joining Method, Personnel) 5

6. 49 CFR 192, Subpart P 192.1007 (b) IDENTIFY THREATS: Consider the following categories of threats to each distribution pipeline. CORROSION NATURAL FORCES EXCAVATION DAMAGE OTHER OUTSIDE FORCE DAMAGE MATERIAL OR JOINT FAILURE (including compression couplings) EQUIPMENT FAILURE INCORRECT OPERATION OTHER CONCERNS (which could affect integrity of the pipeline) 6

7. 49 CFR 192, Subpart P 192.1007 (c) EVALUATE and RANK RISK: Determine the relative importance of each threat, estimate, rank risk posed to your pipeline. Must Consider: Current Threats Potential Threats Likelihood of Failure Associated with EACH THREAT Potential Consequences of Such Failures 7

8. 49 CFR 192, Subpart P 192.1007 (c) EVALUATE and RANK RISK: Determine the relative importance of each threat, estimate, rank risk posed to your pipeline. Must Consider: Current Threats Potential Threats Likelihood of Failure Associated with EACH THREAT Potential Consequences of Such Failures You may subdivide your pipeline into regions with similar characteristics, where similar actions would likely be effective. Subdivisions must be contiguous and consist of mains, services and other appurtenances. Areas with common materials or environmental factors. 8

9. 49 CFR 192, Subpart P 192.1007 (d) IDENTIFY and IMPLEMENT Measures to Address Risk. Implementation of plan to reduce the risk of failures within your distribution system. Plan MUST include an EFFECTIVE Leakage Management Program. (Unless all leaks are repaired when found.) 9

10. 49 CFR 192, Subpart P 192.1007 (e) MEASURE PERFORMANCE Monitor Results, Evaluate Effectiveness. Develop and Monitor Performance Measures from an ESTABLISHED BASELINE to evaluate program effectiveness. Plan MUST include: ₪CATEGORIZED BY CAUSE: Number of Hazardous Leaks either ELIMINATED or REPAIRED as required by 192.703(c.) or total number of leaks if all leaks are repaired when found. ₪ Number of Excavation Damages. ₪ Number of Excavation Tickets. ₪ Total Number of Leaks by Cause, (eliminated or repaired). ₪ Additional Measures deemed necessary by the operator which are needed to evaluate the effectiveness of the IM program in controlling each identified threat. 10

11. 49 CFR 192, Subpart P 192.1007 (f) PERIODIC EVALUATION and IMPROVEMENT Operator MUST re-evaluate THREATS and RISKS on their pipeline and consider the relevance of threats in one location to other areas. Also, MUST define appropriate period for conducting complete program re-evaluations based on system complexity and changes in factors affecting risk of failure. Program Re-evaluation must be at a minimum of 5 years. Operator MUST consider the results of the performance monitoring in these evaluations. 11

12. 49 CFR 192, Subpart P 192.1007 (g) REPORT RESULTS Report on an ANNUAL basis the results of the measures listed in 192.1007 (e)(1)(i) through (e)(1)(iv) as a part of the annual reporting required by 49 CFR 191.11. (Also must report this to the Commission). 12

13. 49 CFR 192, Subpart P 192.1009 REPORTING COMPRESSION COUPLING FAILURES Annually to PHMSA and to the Railroad Commission- Information related to Compression Coupling Failure in regard to HAZARDOUS LEAKS. Must include: LOCATION of failures in the system Nominal Pipe Size Material Type Nature of Failure Coupling Manufacturer Lot number and Date of manufacture Other Information found on the coupling’s markings. 13

14. 49 CFR 192, Subpart P 192.1011 REQIRED RECORDS Records Demonstrating Compliance with Subpart P. Records must be maintained for a minimum of 10 years. Records must include copies of previous versions of the DIM plan, including superseded plans developed under Subpart P. 14

15. 49 CFR 192 Subpart P Unwritten Needs: CAPABLE / COMPETENT DIMP MANAGER. AVAILABILITY of ASSETS for DEVELOPMENT, IMPLEMENTATION and RE-EVALUATION. (MANPOWER, MATERIALS/RESOURCES, TIME) 15

16. 49 CFR Part 192, Subpart P OUTSOURCING: CONTRACTING A PROGRAM DEVELOPER STILL requires you to provide all the information (knowledge) you would normally have with an in-house program. STILL requires you to constantly update the written plan as your system evolves through upgrades and threat mitigation. (This includes having the latest version of a contracted plan.) STILL requires you to maintain and improve records of operations and maintenance pertinent to the DIM Plan. 16

17. 49 CFR 192, Subpart P The DIMP Manager should treat the program like it is his/her baby. The DIMP Manager should look at the distribution system as if it was their castle, eliminating the most likely ways the fortress would be compromised in order of succession (and documenting it), until it is virtually impossible for the enemy (pipeline failures) to storm the walls (or via other routes) and putting the family to the sword. 17

18. THE PUZZLE WILL COME TOGETHER 18

19. THE PUZZLE WILL COME TOGETHER 19 Don’t let this be your castle!

20. THE PUZZLE WILL COME TOGETHER 20 Let this be your castle!

21. 49 CFR 192, Subpart P QUESTIONS ? 21