DIMPInspection Q & A

The Pipeline SuperheroDistribution Integrity Management Program

October 17, 2017LA Department of Natural Resources

Office of Conservation – Pipeline Safety

• Louisiana Administrative Code

• Title 43, Part XIII, Chapter 33

• Code is exactly the same as the federal code

• Form utilized by inspectors is the same form developed by PHMSA. Forms 22, 23, and 24

DIMPRegulations

• The pipeline and hazardous materials safety administration (PHMSA) published the final rule establishing integrity management requirements for gas distribution pipeline systems on December 4, 2009 (74 FR 63906).

• The effective date of the rule is February 12, 2010. Operators were given until August 2, 2011 to write and implement their program.

DIMPHistory

• PHMSA previously implemented integrity management regulations for:

1. Hazardous Liquid and 2. gas transmission pipelines

• These regulations aim to assure pipeline integrity and improve the already admirable safety record for the transportation of energy products.

• Congress and other stakeholders expressed interest in understanding the nature of similarly focused requirements for gas distribution pipelines.

DIMPHistory

The regulation requires operators, such as natural gas distribution companies to develop, write, and implement a distribution integrity

management program with the following elements: • Knowledge • Identify threats • Evaluate and rank risks • Identify and implement measures to address risks • Measure performance, monitor results, and evaluate effectiveness • Periodically evaluate and improve program • Report results

DIMPHistory

• Lack of management involvement• Safety is delegated down in the organization• Cost and minimum compliance standards drive decision-

making• Zero incidents is too expensive

WHY DIMP?

• Management committed to “safe operations”• Rules/procedures drive decision-making• Supervisor-led work culture• Focus of corrective action for deviations is punishment• Zero incidents a concept only

WHY DIMP?Continuously Improve

• Focus is risk-based systems and processes that drive consistent reliable performance

• Leaders communicate expectations and goals and provide adequate resources

• Clear accountabilities and rigorous competency assurance• Zero incident a distant goal

WHY DIMP?Continuously Improve

• Management focus in building and sustaining a zero incident organizational culture

• Management and staff embrace operational discipline as key to assuring human performance (employees and teams take ownership of processes

• Work teams share learning/best practices• Metrics, audits, and management review become tools for

predicting failures and improving (rather than “gotchas”)• Zero incidents are part of the job

WHY DIMP?Continuously Improve

Pipeline Safety

Conservation Program ManagerPipeline Safety

Pipeline Superheroes Ronald Day

Conservation Program ManagerPipeline Safety

Pipeline Superheroes Jamie Burns

Conservation Enforcement SpecialistPipeline Safety

Pipeline Superheroes David Burket

Conservation Enforcement SpecialistPipeline Safety

Pipeline Superheroes Taylor Thomas

Conservation Enforcement SpecialistPipeline Safety

Pipeline Superheroes Jason Cole

Conservation Enforcement SpecialistPipeline Safety

Pipeline Superheroes Suzanne Laird

EngineerPipeline Safety

Pipeline Superheroes Mitchell Buffington

DIMP InspectionTeam (North)

A SUPERHERO is a type of heroic stock character who possesses supernatural or superhuman powers and who is dedicated to fighting crime, protecting the public, and usually battling supervillains.

Ability to know everything on the system!

See what’s going on inside the system!

From reactive to predictive!

DIMPSuperhero

Was the plan written and implemented per the requirement of 192.1005 by 08/02/2011?

OR For a gas system put into service or acquired after 08/02/2011, was a plan written and implemented prior to beginning of operation?

Question 1

• The operator has a DIMP plan written and implemented by August 2, 2011.

• The company shall address LPG or other types of gas transported when applicable.

• The operator shall identify the pipeline system the plan(s) address. • The operator’s DIMP plan shall contain the necessary procedures to

demonstrate that the plan was written and is being implemented. • Make sure the Plan includes all pipe and appurtenances. • Include acquired and new systems put into operation and service

into DIMP plan.

GuidanceQuestion 1

Were commercially available product(s)/templates used in the development of the operator’s written

integrity management plan?

Question 2

• SHRIMP – Simple Handy Risk Integrity Management Program • GPTC Guide Material Appendix G192-8 DIMP • MEA Distribution Integrity Management Plan Preparation Aid • NGA/SGA DIM Framework Document and User’s Guide

GuidanceQuestion 2

Does the operator’s plan assign responsibility, including titles and positions, of those accountable for developing

and implementing required actions?

Question 3

∗ The operator shall identify the positions and responsibilities of personnel who are responsible for carrying out the various elements of the DIMP plan.

GuidanceQuestion 3

Do the written procedures identify or reference the appropriate sources used to determine the following characteristics necessary to assess the threats and

risks to the integrity of the pipeline:Design (e.g. type of construction, inserted pipe, rehabilitated pipe method, materials,

sizes, dates of installation, mains and services, etc.)?Operating Conditions (e.g. pressure, gas quality, etc.)?

Operating Environmental Factors (e.g. corrosive soil conditions, frost heave, land subsidence, landslides, washouts, snow damage, external heat sources, business

districts, wall-to-wall paving, population density, difficult to evacuate facilities, valve placement, etc.)?

Question 4

• The Operator shall be able demonstrate that they have looked at all available source records to find information from past design, operations, or maintenance such as coating, material, etc.

• The Operator shall specifically list which documents were used to meet question 4.

• The Operator shall gather or use reasonably available data on the entire pipeline that could be

GuidanceQuestion 4

• relevant to performing their threat assessment, risk evaluation or as needed to group like facilities.

• The Plan shall identify the records containing the appropriate characteristics of the pipeline’s design to assess each threat category and subcategory to the operator’s pipeline.

• The Plan shall identify the records containing the appropriate characteristics of the pipeline’s operating conditions to assess each threat category and subcategory to the operator’s pipeline.

• The Plan shall identify the records containing the appropriate environmental characteristics to assess each threat category and subcategory to the operator’s pipeline.

GuidanceQuestion 4

Do the written procedures require the consideration of information gained from past design, operations, and

maintenance (e.g. O&M activities, field surveys, One-Call system information, excavation damage, etc.)?

Question 5

• Operator shall demonstrate that they have looked at source records to find information gained from past design, operations, or maintenance such as coating, material, etc.

• Operator should specifically list which documents where used to meet question 5.

• Operator shall gather or use reasonably available data on the entire pipeline system that could be relevant to performing their threat assessment, risk evaluation or as needed to group like facilities.

• Plan shall identify the records used to consider information gained from past design, operations, and maintenance characteristics to assess each threat category and subcategory to the operator’s pipeline system.

GuidanceQuestion 5

Does the plan include a written explanation of the mechanisms or procedures to identify additional

information that is needed to fill gaps due to missing, inaccurate, or incomplete records?

Question 6

• There shall be a written explanation of the mechanisms or procedure for identifying needed missing, inaccurate or incomplete data.

• The operator shall adequately identify missing, inaccurate or incomplete data.

GuidanceQuestion 6

Does the plan list the additional information needed to fill gaps due to missing, inaccurate, or incomplete records?

Question 7

• Operator shall have a list of missing, inaccurate, or incomplete records

• Operator shall demonstrate that they are collecting, reviewing, and analyzing the data after it is collected.

GuidanceQuestion 7

Do the written mechanisms or procedures specify the means to collect the additional information over time

through normal activities conducted on the pipeline (e.g. design, construction, operations or maintenance

activities)?

Question 8

• Operator’s plan shall clearly specify the written explanation of the mechanisms or procedure to collect additional information.

• Operator shall collect data as specified in the procedure.

GuidanceQuestion 8

Do the written mechanisms or procedures require the capture and retention of data on any new pipeline

installed?

Question 9

• Written mechanisms or procedures shall include a process to record the necessary data about new pipelines.

• The data shall include, at a minimum, the location where the new pipeline is installed and the material of which it is constructed.

GuidanceQuestion 9

• Does the captured and retained data on any new pipeline include, at a minimum, the location where the new pipeline is installed and the material from which it is constructed?

Question 10

• Material is more than just “steel” or “plastic.” It should include the specification, grade of steel or type of plastic, manufacturer, coating, etc. In accordance with the definition of “pipeline” in §192.3, this includes valves and other appurtenances through which gas flows.

• Written mechanisms or procedures shall include a process to record the location and material of a new pipeline.

GuidanceQuestion 10

Has the operator demonstrated an understanding of its pipeline, which, to the extent known, should include the

approximate location and material of its pipeline?

Question 11

• Operator shall have an adequate understanding of their pipeline.

• Operator shall know the approximate location and material of its pipeline.

• Operator shall have adequate maps and records that show the approximate location and materials of its pipeline.

GuidanceQuestion 11

Does the documentation provided by the operator demonstrate implementation of “Knowledge of the

system”?Has the operator demonstrated an understanding of its

system?

Question 12 & 13

• Plan demonstrates Knowledge of the system and the operator shall demonstrate an understanding of its distribution system.

• Operator shall have adequate maps and records. • Operator shall be attempting to fill information gaps.

GuidanceQuestion 12 &13

DIMP ManagementBaseball Heroes

George Brett is one of four players in MLB history to accumulate 3,000 hits, 300 home runs, and a career .300 batting average (the others are Stan Musial, Willie Mays, and Hank Aaron

DIMP ManagementBaseball Heroes

Two-time National League MVP Dale Murphy called Nolan Ryan “the only pitcher you start thinking about two days before you face him.” Ryan’s career spanned four decades and when all was said and done, he retired with 324 wins and a major league-record 5,714 strikeouts. “Robin Ventura decided to take on Nolan Ryan”

DIMP ManagementBaseball Heroes

In the third inning of Game Three of the 1932 World Series, Babe Ruth came to the plate to face Cubs starter Charlie Root. In what may have been an attempt to rattle the legendary slugger, the Cubs bench decided to heckle the Babe mercilessly. Ruth obliged his would-be tormentors by barking right back at them. After taking strike one, Ruth gestured with his hand in an indeterminate direction. After taking a second strike, Ruth repeated the gesture. It's unknown if Ruth was pointing at Root, the Cubs bench or the centerfield seats, but on the next pitch Ruth slammed a home run of at least 440 feet over the centerfield wall

DIMP ManagementBaseball Superheroes

MONEYBALL

∗ Statistics such as stolen bases, runs batted in, and batting average, typically used to gauge players, are relics of a 19th-century view of the game and the statistics available at that time. The book argues that the Oakland A's' front office took advantage of more analytical gauges of player performance to field a team that could better compete against richer competitors in Major League Baseball (MLB).

∗ Rigorous statistical analysis ”sabermetrics”, an approach which consists of more sophisticated analyses of baseball statistics, had demonstrated that on-base percentage and slugging percentageare better indicators of offensive success, and the A's became convinced that these qualities were cheaper to obtain on the open market than more historically valued qualities such as speed and contact. These observations often flew in the face of conventional baseball wisdom and the beliefs of many baseball scouts and executives.

∗ By re-evaluating the strategies that produce wins on the field, the 2002 Athletics, with approximately US$44 million in salary, were competitive with larger market teams such as the New York Yankees, who spent over US$125 million in payroll that same season. Because of the team's smaller revenues, Oakland is forced to find players undervalued by the market, and their system for finding value in undervalued players has proven itself thus far. This approach brought the A's to the playoffs in 2002 and 2003.

DIMP ManagementBaseball Superheroes

In identifying threats, do the written mechanisms or procedures include consideration of the following categories of threats to each gas

distribution pipeline? • Corrosion • Natural Forces • Excavation Damage • Other outside Force Damage • Material or Weld • Equipment Failure • Incorrect Operation

Question 14

• The procedures shall include a review of the 8 primary threats. All of the threats required by the rule shall be adequately considered and/or evaluated

• Specific threats eliminated from consideration shall have adequate justification

• Operator shall use relevant operating and maintenance records in evaluating each threat.

• Procedures shall adequately describe the requirements for identifying and evaluating threats

• Operator shall use reasonable or appropriate subdivision of threats

GuidanceQuestion 14

Did the operator consider the information that was reasonably available to identify existing and potential

threats?

Question 15

• The procedures shall include a review of the potential threats.

• Operator shall use all reasonably available records. • Operator shall reasonably subdivide the system to

identify existing and/or potential threats • Operator’s plan shall consider data from external

sources to identify potential threats.

GuidanceQuestion 15

Does the plan subdivide the primary threats into subcategories to identify existing and potential threats?

Question 16

• Information only question• Systems are grouped at a minimum using the eight

primary leak categories on the gas distribution annual report. Operators may develop their own subcategories of threats or use the subcategories found in guidance material.

GuidanceQuestion 16

In identifying threats did the information considered include any of the following? • Incident and leak history • Corrosion control records • Continuing surveillance records • Patrolling records • Maintenance history • Excavation damage experience• Other – Describe

Question 17

• Operator shall use reasonably available information to develop knowledge to identify threats.

GuidanceQuestion 17

Does the plan categorize threats as either “system-wide” or “localized”?

Question 18

• This is an information only question• Information regarding the operator’s threat

categorization is important to determine whether the implemented measures to reduce risk are appropriate and being implemented in the necessary areas.

GuidanceQuestion 18

Do the written procedures consider, in addition to the operator’s own information, data from external sources (e.g. trade

associations, government agencies, or other system operators, etc.) to assist in identifying potential threats?

Question 19

• This is an information only question• Operators need to review advisory bulletins and reports

issued by PHMSA, NTSB, and State pipeline regulatory agencies. Operators may find comparing leak rates on their system to national statistics useful.

GuidanceQuestion 19

Does the documentation provided by the operator demonstrate implementation of the element “Identify

Threats”?

Question 20

• Operator shall adequately identify threats to their system. • Operator shall consider threats specific to their system. • Operator shall consider threats identified in reasonably

available external sources. • Operator shall subdivide the system into regions with similar

characteristics and for which similar actions are likely to be effective in reducing risk where subdivision is considered necessary.

GuidanceQuestion 20

Was the risk evaluation developed fully or in part using a commercially available tool?

Question 21

• This is an information only question• the operator may have used a commercial tool to

develop their replacement program but used subject matter experts to evaluate risks with different measure to address risk.

GuidanceQuestion 21

Do the written procedures contain the method(s) used to determine the relative importance of each threat and

estimate and rank the risks posed? Briefly describe the method.

Question 22

• A comprehensive risk analysis process shall be adequately developed

• All portions of pipelines shall be included in the risk analysis • The process shall adequately consider unique risk factors when

using a "standard" risk model • The risk analysis process shall be adequately documented • The risk analysis process shall adequately consider all required risk

factors • Risk weighting factors shall be adequately validated or justified • Likelihood or consequence of pipeline failures shall be adequately

considered in the risk analysis

GuidanceQuestion 22

Do the written procedures to evaluate and rank risk consider (question contains a table to verify each of the 8

primary threats for the questions below): 23. Each applicable current and potential threat? 24. The likelihood of failure associated with each threat? 25. The potential consequence of such a failure?

Question 23-25

Has all information collected during development of knowledge of the system and the threat identification been used in the risk evaluation? Did the operator develop weighting factors for each threat specific to their system(s)? Did the operator estimate the likelihood and consequences of failure for each threat?

• The Plan shall contain procedures for determining the applicable potential threats, the likelihood of the failure, or the potential consequence of the failure.

GuidanceQuestion 23-25

• If subdivision of system occurs, does the plan subdivide the system into regions with similar characteristics and for which similar actions are likely to be effective in reducing risk?

• Briefly describe the approach.

Question 26

• Operator should subdivide its system into regions that have similar characteristics and for which similar actions are likely to be effective in reducing risk.

• Subdivision combines systems with differing characteristics and for which similar actions are likely to be effective in reducing risk.

GuidanceQuestion 26

Is the method used to evaluate and rank risks reasonable?

Question 27

• This is an information only question• A risk evaluation method includes the algorithm used

(how risks are calculated) and how the algorithm is implemented

GuidanceQuestion 27

Are the results of the risk ranking supported by the risk evaluation model/method?

Question 28

• Risk analysis shall adequately identify dominant risk factors • The impact of uncertainties on the results shall be adequately considered • The risk analysis shall be adequately performed and adequately followed• Operator shall conducted a risk assessment • Risk assessment shall prioritize pipeline segments • The process the operator describes in the procedure shall sufficiently

documented so an inspector can make a reasonable determination as to the accuracy and thoroughness of the process.

• Procedures shall contain adequate detail to allow for a clear understanding of the process.

GuidanceQuestion 28

Did the operator validate the results generated by the risk evaluation model/method?

Question 29

• Operator shall validate the results of the risk evaluation. • Operator history shall be consistent with the output of

the risk evaluation model. • Information provided by validation team members shall

concur with results. • The operator shall have documentation validating the

ranking results.

GuidanceQuestion 29

Does the documentation provided by the operator demonstrate implementation of the element “Evaluate and

Rank Risk”?

Question 30

• Operator shall perform a risk evaluation • Operator shall validate the results of the risk evaluation. • Operator history shall be consistent with the output of the risk

evaluation model. • Information provided by validation team members shall concur with

results. • The operator shall have documentation validating the ranking

results. • Procedures shall be detailed enough or clear enough so that anyone

who has to use them can understand and follow them.

GuidanceQuestion 30

Does the plan include procedures to identify when measures, beyond minimum code requirements specified outside of Part 192 Subpart P, are required to reduce risk?

Question 31

• Procedure shall be is in place to identify additional measures to prevent a pipeline failure and to mitigate the consequences of a pipeline failure.

• The procedure shall identify the need for measures to reduce risk. • The procedure shall require a schedule for implementation of measures to reduce

risk. • The procedure for identifying additional measures shall be based on identified

threats to each pipeline segment and the risk analysis. • The procedure for evaluating additional preventive and mitigative measures shall

adequately describe the method used to assure the appropriate selection of the risk mitigative measures intended to reduce risk for a specific threat.

• Procedures shall contain adequate detail or clarity to allow individuals that were not previously involved in the process to implement them.

• The process shall adequately require a documented justification for decisions regarding additional preventive and mitigative measures.

GuidanceQuestion 31

When measures, beyond minimum code requirements specified outside of Part 192 Subpart P, are required to

reduce risk, does the plan identify the measures selected, how they will be implemented, and the risks they are

addressing?

Question 32

• The risk mitigative measures shall specifically address identified risk factors. • The plan shall provide a process to implement the mitigative measures. • The plan shall provide a schedule for implementation of mitigative measures. • The operator shall produce documentation of measure already in progress. • All required risk factors shall be adequately considered in the preventive and

mitigative evaluation process • The impact of preventive or mitigative actions on risk shall be adequately

evaluated. • Risk mitigative measures housed in other operator programs shall be included

or referenced in the DIMP plan.

GuidanceQuestion 32

Does the plan include an effective leak management program (unless all leaks are repaired when found)

1. Locate the leaks in the distribution system; 2. Evaluate the actual or potential hazards associated with these leaks; 3. Act appropriately to mitigate these hazards; 4. Keep records; and 5. Self-assess to determine if additional actions are necessary to keep people and property safe.

Question 34

• Leaks graded as non-hazardous are becoming hazardous leaks before repair, and the operator has not self-assessed and made appropriate adjustments to its leak management program.

• The operator shall recheck leaks within the scheduled time period. • The operator shall evaluate the leak program to determine if it is effective. • The operator shall assure consistency in leak grading across the system. • The procedure shall be sufficiently documented to allow an inspector to

make a reasonable determination as to the accuracy and thoroughness of the process.

• A leak management program shall be included or referenced in the DIMP plan. (Not applicable if an operator repairs all leaks when found).

GuidanceQuestion 34

Does the documentation provided by the operator demonstrate implementation of the measures, required by

Part 192 Subpart P, to reduce risk?

Question 35

• Measures to reduce risk shall be performed according to operator’s procedure.

• Operator shall identify measures to reduce risk when required by their risk evaluation.

• Operator shall schedule or obtain resources to perform measures to reduce risk.

• Operator shall keep records demonstrating implementation of measures to reduce risk.

GuidanceQuestion 35

36. Does the plan contain procedures for how the operator established a baseline for each performance measure? 37. Does the plan establish a baseline for each performance measure? 38. Does the operator have procedures to collect the data for each performance measure? 39. Do the written procedures require theoperator to monitor each performancemeasure?

Questions 36-39

• Operator shall have threat-specific performance metrics when needed.

• The process the operator describes in the procedure shall be sufficiently documented so an inspector can make a reasonable determination as to the accuracy and thoroughness of the process.

• Operator shall plan to establish a baseline for performance measures where historical data for a baseline does not exist.

GuidanceQuestions 36-39

When measures are required to reduce risk, do the written procedures provide how their effectiveness will be

measured?

Question 40

• Operator shall include an explanation of how the effectiveness of measures to reduce risk will be measured.

• Performance measures selected shall measure effectiveness of the measure.

• If Performance measures indicate that a risk reduction measure is not effective, the operator shall take actions to revise/replace the measure.

GuidanceQuestion 40

Can the performance measures identified by the operator in the plan be counted, monitored, and supported?

Question 41

• This is an information only question• Performance measures should be "SMART" - specific,

measurable, acceptable, realistic to achieve and time-bound with a deadline

GuidanceQuestion 41

Does the documentation provided by the operator demonstrate implementation of the element “Measure

Performance, Monitor Results, and Evaluate Effectiveness”?

Question 42

• Operator shall collect performance measure data. • Operator shall analyze the performance measure data to

monitor the progress of the risk reduction measure. • Operator shall evaluate the data to determine if the

measure to reduce risk was effective. • If the Operator has determined that a risk reduction

measure is not effective, the Operator shall take action to revise/replace/enhance the measure.

GuidanceQuestion 42

Do the written procedures for periodic review include: a. Frequency of review based on the complexity of the system and changes in factors affecting the risk of failure, not to exceed 5 years? b. Verification of general information (e.g. contactinformation, form names, action schedules)? c. Incorporate new system information? d. Re-evaluation of threats and risk? e. Review the frequency of the measures to reduce risk? f. Review the effectiveness of the measures to reduce risk? g. Modify the measures to reduce risk and refine/improveas needed (add new, modify existing, or eliminate if no longer needed)? h. Review performance measures, their effectiveness, and if they are not still appropriate, refine/improve them?

Question 43

• An operator shall have a DIMP evaluation procedure. • Adequate procedures shall be developed for conducting IM program

effectiveness evaluations • The procedure shall identify the frequency of the periodic evaluation. • The procedure shall adequately include reviews or audits of IM programs • Performance goals shall be included in the procedure • An operator shall change its DIMP, as required to address information obtained

through annual reviews, program evaluations, or whenever any change occurs that would materially alter any of the elements in the DIMP.

• An operator shall make the changes to the DIMP or implement the changes to the DIMP when and where the program evaluation identified changes were required.

• An operator shall thoroughly document the changes including the purpose, content and date completed.

GuidanceQuestion 43

Does the plan contain a process for informing the appropriate operating personnel of an up-date to the plan?

Question 44

• This is an information only question• Verify provisions for operator internal organizational

communication exist to establish understanding of and support for changes to the integrity management program.

• The type of changes that need to be communicated within the operator’s organization would include revisions to data collection, new threats identified, reduction of threats, implemented measures to reduce risk, or changes that affect the overall manner in which an operator is implementing its DIMP

GuidanceQuestion 44

Does the plan contain a process for informing the appropriate regulatory agency of a significant up-date to

the plan?

Question 45

• This is an information only question• The federal rule does not include a requirement to

inform PHMSA of changes to an operator’s DIMP plan

GuidanceQuestion 45

Does the documentation provided by the operator demonstrate implementation of the element “Periodic

Evaluation and Improvement”?

Question 46

• A DIMP program evaluation shall be adequately performed

• Adequate actions shall be identified to improve the DIMP based on a review of the evaluation

• Actions identified by the DIMP program evaluation shall be adequately implemented

• Response to performance measures indicating poor performance shall be adequately documented

GuidanceQuestion 46

Does the plan contain or reference procedures for reporting, on an annual basis, the four measures listed in 192.1007(e)(1)(i) through (e)(1)(iv) to PHMSA as part of

the annual report required by § 191.11 and the State regulatory authority?

Question 47

• (i) Number of hazardous leaks either eliminated or repaired as required by § 192.703(c) of this subchapter (or total number of leaks if all leaks are repaired when found), categorized by cause;

• (ii) Number of excavation damages; • (iii) Number of excavation tickets (receipt of information by the

underground facility operator from the notification center); • (iv) Total number of leaks either eliminated or repaired, categorized

by cause; • The operator’s procedures shall address submitting the performance

measures. • The operator’s procedures shall include all the measures specified

by the Rule.

GuidanceQuestion 47

When required by the State, does the plan identify the specific report form, date, and location where it is to be

submitted?

Question 48

• Annual report with specific leak information is required to be submitted by March 15th annually

• Not required to submit DIMP measures separately

GuidanceQuestion 48

Has the operator submitted the required reports?

Question 49

• Operator shall submit required reports. • Reports shall be submitted electronically unless the

Operator gets permission to submit hard copies.

GuidanceQuestion 49

Does the operator have procedures to collect the information necessary to comply with the reporting

requirements of 192.1009?

Question 50

• The operator’s DIMP plan shall address submitting information about mechanical fitting failures which result in hazardous leaks.

• Apparent cause analysis shall be integrated into the IM program. • The appropriate actions shall be specified to prevent recurrence of a

problem that could lead to an integrity concern. • Operator shall report hazardous mechanical fitting failures, as

appropriate. • Mechanical fitting failures which result in a hazardous leak may be

submitted throughout the year or at one time by March 15th for the previous calendar year.

GuidanceQuestion 50

Does the operator have procedures specifying which records demonstrating compliance with Subpart P will be

maintained for at least 10 years?

Question 51

• The procedure shall require that all required records be maintained for the ten year minimum requirement.

• The Rule does not require that documents to support any decision, analysis, and process developed and used to implement and evaluate each element of the integrity management program be maintained but they are useful.

• This set of documents includes those developed and used in support of any identification, calculation, amendment, modification, justification, deviation and determination made, and any action taken to implement and evaluate any of the program elements.

• Operators must retain records related to these reviews for 10 years after they are conducted. If the review results in revision of the DIMP plan, then records associated with that revision must be retained for 10 years. If the review reaffirms the existing DIMP plan, without change, then the records associated with the original DIMP plan, particularly documents demonstrating knowledge of the system, must be retained for another ten years.

GuidanceQuestion 51

Does the operator have procedures specifying that copies of superseded integrity management plans will be

maintained for at least 10 years?

Question 52

• The operator shall have a procedure specifying that copies of superseded integrity management plans will be maintained for at least 10 years.

• C.6.2 Must I retain all records I consider in developing my DIMP under §192.1011? An operator must maintain records demonstrating compliance with the requirements of Subpart P for at least 10 years including those records that specifically detail compliance with the elements in 192.1007. This includes documents related to the development (or subsequent review) of your DIMP plan.

GuidanceQuestion 52

Has the operator maintained the required records?

Question 53

• The operator shall keep the required records or other documentation for the specified time period.

• The operator shall keep the superseded integrity management plans for the specified time period.

• The operator shall have records or other documentation to support any of the above requirements.

• The operator shall have records or other documentation to support the above requirements and the records or other documentation that are sufficient to prove compliance.

GuidanceQuestion 53

Stay Tuned…DIMP Inspection

Team (South)

Any Questions?