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Some Dissatisfaction With DIMP
While distribution companies and state regulators seem to be satisfied with the general outlines of the proposed distribution integrity management program (DIMP) announced on June 25 by the Pipeline and Hazardous Materials Safety Administration (PHMSA), a number of questions are being raised by both groups about some of the proposal's murky details.
The American Gas Association held a workshop in Chicago on the DIMP on Aug. 12 13. About 120 people attended, including PHMSA officials and representatives of the National Association of Pipeline Safety Representatives (NAPSR). There were rumblings in the corridors. Subsequently, both the AGA and NASR asked PHMSA to extend the comment deadline, which PHMSA did, from Sept. 23 to Oct. 23.
PHMSA's proposed DIMP is an effort to force state regulators and intrastate pipelines to beef up their integrity management programs. To the extent that the proposed rule follows the recommendations in a 2005 report PHMSA published, which was based on ideas of stakeholders, it contains few surprises and its outlines are acceptable. However, there are more than a few sticking points among the details of the proposed rule. Philip Sher, program manager of Connecticut's pipeline safety program and chairman of the NAPSR DIMP task group, says, "Questions about application of requirements can be tricky. Details can take a good rule and make it burdensome. We shouldn't be looking at procedures that are 150 pages long."
Chief among the concerns for state regulators and industry is PHMSA's intention to require mandatory reporting of plastic pipe and associated fittings failures to the agency within 90 days. Currently, the Plastic Pipe Data Committee, of which the American Gas Association is the administrator, gets voluntary reports from owners of 83 percent of the plastic pipe miles in the United States, according to Phil Bennett, the senior managing counsel for the AGA. However, not all distribution companies have access to that data. Moreover, in the proposed rule, PHMSA wonders out loud whether the PPDC is "adequately objective to evaluate and report to the industry" or whether the agency should seek an independent third party to do the number crunching. PHMSA, which is a member of that committee, is concerned that companies without access to the PPDC data would lack the information necessary to do the kind of thorough risk analysis required by the DIMP. Bennett says AGA members oppose setting up a parallel, mandatory federal data base.