On April 10 and 11, APGA’s John Erickson briefed the attendees of the Tennessee Gas Association Distribution & Operations Conference in Murfreesboro, Tenn., on current issues affecting operators of gas utilities. His first presentation on April 10 addressed recent and pending pipeline safety regulations as well as APGA programs to assist members to improve the safety and efficiency of their operations. John began by noting that no significant regulations have been issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in the past 12 months. Several regulations are pending, including changes to plastic pipe regulations, operator qualification regulations and transmission regulations. The first two have gone through public comment and could be issued at any time; however, the Executive Order requiring agencies to remove existing regulations to offset the cost of new regulations has added an extra step in PHMSA’s normal rulemaking process. The transmission rule is still undergoing PHMSA’s Advisory Committee review and cannot be issued as a final rule until that process has been completed.
He continued with an overview of APGA’s System Operational Achievement Recognition (SOAR) , Gas Overall Awareness Level (GOAL), and benchmarking programs. He noted that eight Tennessee utilities have been awarded SOAR, more than any other state. He also noted that 33 Tennessee utilities were using the APGA GOAL program to measure the effectiveness of their public awareness programs with customers and non-customers living near their lines.
The next day, John provided his thoughts on how operators could best prepare for state audits of their Distribution Integrity Management Programs (DIMP). He noted that there are currently 80 active Simple, Handy, Risk-based Integrity Management Plan (SHRIMP) subscribers in Tennessee. First, he advised to make sure your DIMP plan is up to date. The DIMP rule requires operators to update plans at least every five years, but if an operator wrote into its plan that it would re-evaluate its plan more frequently, then that operator must perform the reviews on the more frequent schedule.
Second, he urged attendees to make sure they were completely familiar with all aspects of their plan – especially any action items such as additional risk reduction measures called for in the plan and performance measures. Finally he noted that the PHMSA Inspection Form 24 used to audit implementation of DIMP is publicly available from PHMSA and under the Resources tab in the SHRIMP program. Downloading and using that form prior to the audit would be the best way to ensure the audit goes smoothly.
For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at
jerickson@apga.org.