Transcript Document

2010 Western Regional
Gas Conference
DIMP- Beyond the Final Rule
August 24, 2010
Tempe, AZ
Bruce L. Paskett P.E.
Principal Compliance Engineer
NW Natural
NW Natural Company Background
Company founded in 1859
Operate in Oregon and SW Washington
Serve approximately 670,000 residential,
commercial and industrial customers
Designed, constructed, own and operate 603 miles
of transmission main and 21,000 miles of
distribution mains and services
Company has installed over 160,000 single family
residential EFVs since 1999
NW Natural and Pipeline Safety
NW Natural is committed to the Safe, Reliable
and Cost Effective delivery of natural gas to our
customers.
NW Natural and Pipeline Safety
Pipeline Integrity Management Programs Cast Iron Replacement Program-1983 to 2000
 Bare Steel Replacement Program-2001
 Natural Forces (Geohazard) Program-2001
 Transmission Integrity Management Program-2002
 Distribution Integrity Management Program-1983
The Evolution of DIMP
 Pipeline Safety Improvement Act of 2002- Dec 2002
 D.O.T. Inspector General Testimony – July 2004
 AGF Study- January 2005
 PHMSA Phase 1 Investigations- December 2005
 GPTC DIMP Guidance- December 2006
 PIPES Act- December 2006
 DIMP NOPR- June 2008
 DIMP Final Rule- December 4, 2009
Elements of a DIMP Program
Written DIMP Integrity Management Plan must
contain procedures for developing and implementing:
 Knowledge
 Identify threats
 Evaluate and rank risks
 Identify and implement measures to address risks
 Measure performance, monitor results, and
evaluate effectiveness
 Periodic evaluation and improvement
 Report results
Elements of a DIMP Program
192.1007(b) Identify threats
 Corrosion
 Natural forces
 Excavation damage
 Other outside force damage
 Material, weld or joint failure, including
“compression couplings”
 Equipment failure
 Incorrect operation
 Other
Elements of a DIMP Program
 Based on the Final DIMP Rule, operators had
all the information they needed to “Just Do it!” ,
right ?
 Not exactly. The DIMP Rule has continued to
evolve since the Final Rule. The “Final Rule”
was not final!
DIMP - Beyond the Final Rule
Post-Rule “Highlights” Effective Leak Management Program
 Aboveground leak reporting
 Excavation Damage Prevention Programs
 New Annual Report Form (Form F 7100.1-1)
 Compression couplings vs. mechanical fittings
 DIMP FAQs / Inspection Form / Pilot Audits
 EFVs
 Low stress transmission lines
DIMP - Beyond the Final Rule
Effective Leak Management Program 1007(d) Identify and implement measures to address
risks. Required as a risk mitigation measure under
DIMP unless all leaks are repaired when found
 Phase 1 Report defines effective LEAKS ProgramLocate the leak
Evaluate it’s severity
Act appropriately to mitigate the leak
Keep records
Self assess
 Inspections will focus on Leak Programs
DIMP - Beyond the Final Rule
192.1007(d) Performance Measures Number of hazardous leaks eliminated or repaired
by cause
 Number of excavation damages
 Number of excavation tickets
 Total number of leaks eliminated or repaired by
cause
 Any additional measures the operator determines
are necessary
DIMP - Beyond the Final Rule
192.1001 Hazardous Leak was defined:
 Hazardous Leak means a leak that represents an
existing or probable hazard to persons or property
and requires immediate repair or continuous action
until the conditions are no longer hazardous
 Mirrors the definition of a hazardous (Grade1) leak
contained in the GPTC guide
 GPTC provides excellent guidance for classification
of below ground leaks
 No consistent definition or reporting criteria for
above ground leaks
DIMP - Beyond the Final Rule
What is a “Hazardous Aboveground Leak” ?
AGA Proposed DefinitionAn unintentional escape of gas from above ground
piping or related gas facilities that requires immediate
make-safe action, because:
 On outside piping, it:
Can be seen, heard or felt (e.g.-causes the blowing
off of leak detection soap); and
Is in a location that may endanger the general
public or property (e.g.-requires an immediate
evacuation to protect public safety)
DIMP - Beyond the Final Rule
What is a “Hazardous Aboveground Leak” ?
 On inside piping, it:
Can be seen, heard or felt (e.g.-causes the blowingoff of leak detection soap); and
Is in a location that may endanger the general
public or property (e.g.-requires an immediate
evacuation to protect public safety) or it generates a
reading of 20% LEL or more in the general
atmosphere of the structure
DIMP - Beyond the Final Rule
What is a “Reportable Aboveground Leak” ?
An aboveground leak determined to be hazardous
based on the criteria defined above is reportable
 Minor escapes of gas (non-hazardous releases) at threads
on sound piping or at fittings that are detectable only with
instruments in direct proximity or that give only slight
indications with leak detection soap need not be considered
as leaks if they could be eliminated by lubrication,
adjustment or tightening, even if the operator elects to
reconstruct the piping or replace parts in order to eliminate
the minor escape of gas
DIMP - Beyond the Final Rule
Effective Excavation Damage Prevention Program-
 DIMP NOPR required enhancement of the excavation
damage prevention program required under 192.614.
However, the DIMP Final Rule is silent on this issue
 Don’t be complacent! You must be able to demonstrate
you have an effective excavation damage prevention
program
 Why? Because excavation damage presents the
greatest threat to distribution pipeline safety
Allegro
And Now, the New “Small Buckets”
(i.e., 2nd-Level Causes): Hazards, Actors
Ener gy Consult ing
Number of Incidents, 99-03
38%
250
200
29%
Third
Party
150
Vehicle
100
50
12%
7%
3%
Oper
0
Corrosion
Nat'l
Forces
Excav/
Mech
Dam'g
Fire
First
5%
Other
Outside
Mat'l/
Weld
7%
Unk.
Oper
Misc.
Equip/
Oper
Error
Other
© Cheryl J. Trench, 2004
DIMP - Beyond the Final Rule
Excavation Damage Prevention Program Elements 192.614- Damage Prevention Program
 192.613- Public Awareness Program / RP 1162
 Phase 1 Report / 2006 PIPES Act- Nine Elements.
Ensure your state has a comprehensive program.
Note: PHMSA ANPRM- state program effectiveness
 DIMP Reporting Metrics for Excavation Damage-
(Excavation Damages / Tickets)
 Consider EDPG internal metrics to evaluate “root
causes” of excavation damages
DIMP - Beyond the Final Rule
PHMSA Revised Annual Report Form (F 7100.1-1)
 Revised to allow reporting of DIMP performance
measures, number of EFVs installed on SFR
services and mechanical fitting failure data
 Submit all DIMP metrics on 2010 Annual Report
(due March 15, 2011), except for mechanical
fittings
 Gather mechanical fitting failure data beginning on
January 1, 2011 for reporting on 2011 Annual
Report (due March 15, 2012)
DIMP - Beyond the Final Rule
Compression Couplings vs. Mechanical Fittings-
 Final Rule (192.1009) required reporting of
“compression coupling failures” that result in
hazardous (Grade 1) leaks, but DIMP Rule included
a NOPR
 Compression couplings essentially join pipe-to-pipe
 PHMSA has determined that they want to gather
“mechanical fitting failures” instead
 Each (hazardous leak) failure requires a one page
data submission in the Annual Report
DIMP - Beyond the Final Rule
Mechanical fitting definition-
 Includes stab, nut follower and bolt type mechanical
fittings
 Steel to steel, steel to plastic and plastic to plastic
 Includes service or main tees, tapping tees,
transition fittings, valves, end caps, etc
 Essentially any fitting that is not welded or fused!
DIMP - Beyond the Final Rule
Additional DIMP GuidanceFrequently Asked Questions (FAQs-8/3/10) and DIMP
Webcast (soon!). Provide additional clarity about;
 EFVs
 GPTC Guidance
 Farm taps
 Leak management
 Reporting of performance measures
 Mechanical fitting failure reporting
 Alternative inspection intervals
DIMP - Beyond the Final Rule
DIMP Inspection Form and Pilot Audits-
 PHMSA / NAPSR team has developed draft DIMP
Inspection Form
 “Pilot Audits” will be used to evaluate draft form
 First audit- Virginia, September 14-15
 Additional pilot audits in November & December
 Revise draft Inspection Form prior to end of year
 Three pilot audits in January and February
 Finalize DIMP Inspection Form
DIMP - Excess Flow Valve (EFV) Requirements
 Excess Flow Valve Rule (1998)- Required customer
notification of availability of EFVs for all new or replaced
single family residential services
 DIMP Phase 1 Report-Four study groups concluded that
EFVs can be a valuable risk mitigation tool, but should not
be mandated
 2006 PIPES Act-Congress mandated EFVs only for new and
replaced single family residential services after June 1, 2008
 DIMP Final Rule-Requires operators to identify threats,
evaluate risks, and implement measures to address risks
 GPTC DIMP Guidance suggests that operators consider the
expanded use of EFVs as one possible additional / or
accelerated action to address risk
DIMP - EFV Requirements
 192.383 Excess Flow Valve installation
 (a) Definitions Replaced service line means a natural gas service line
where the fitting that connects the service line to the main
is replaced or the piping connected to this fitting is
replaced
 Service line serving single-family residence means a
natural gas service line that begins at the fitting that
connects the service line to the main and serves only one
single-family residence
DIMP - EFV Requirements
 192.383 Excess Flow Valve installation
 (b) Installation Required. An excess flow valve
(EFV) installation must comply with the
performance standards in 192.381. The operator
must install an EFV on any new or replaced
service line serving a single-family residence
after February 2, 2010, unless one or more of the
following conditions is present:
DIMP - EFV Requirements
192.383 Excess Flow Valve Installation
 (b) Installation Required. Exceptions:
(1) The service line does not operate at a pressure of 10
psig or greater throughout the year
(2) The operator has prior experience with contaminants
in the gas stream that could interfere with the EFV’s
operation or cause loss of service to a residence
(3) An EFV could interfere with necessary O & M
activities, such as blowing liquids from the line; or
(4) An EFV meeting performance standards of 192.381 is
not commercially available to the operator
DIMP - EFV Requirements
192.383 Excess Flow Valve Installation
(c) Reporting. Each operator must, on an annual
basis, report the number of EFVs installed
pursuant to this section as part of the annual
report required by 191.11
Note: Part E of the new Annual Report Form
requires reporting of the “Number of EFVs In
System at End of Year on Single-family
Residential Services”.
EFV Installation Location
DIMP - EFV Requirements
SUMMARY Congress required installation of EFVs on SFR after
June 1, 2008 in 2006 PIPES Act
 Final DIMP Rule requires EFVs on all new and
replaced service lines serving single-family
residences after February 2, 2010
 End of Story, Right? The story continues……….
NTSB Recommendation P-01-2
 NTSB issued P-01-2 on June 22, 2001 in
response to the South Riding, VA incident
 PHMSA should “require that excess flow
valves be installed in all new and renewed gas
service lines, regardless of a customer’s
classification, when the operating conditions
are compatible with readily available valves”.
NTSB Recommendation P-01-2
NTSB Safety RecommendationsThe Pipeline and Hazardous Materials Safety
Administration is required by law to respond to
Safety Recommendations issued by the
National Transportation Safety Board (NTSB),
an independent federal agency charged by
Congress with investigating significant
hazardous materials accidents/incidents.
Beyond DIMP - Large Volume EFV
 Industry believed that the single-family residential EFV
requirements in the 2006 PIPES Act and the mandated
and risk-based use of EFVs under the DIMP Rule is
consistent with NTSB recommendation P-01-2
 However, in response to the NTSB recommendation,
PHMSA formed a “Large EFV Team” to study the issue
beginning June 23, 2009
 NTSB reiterated P-01-2 for all classes of customers in a
September 21, 2009 letter to PHMSA.
PHMSA Large EFV Team
Organizations Represented
PHMSA soliciting input from following stakeholders:
Regulators
Public
PHMSA, OPS
NTSB
States, NAPSR
EFV Manufacturers
Fire Services
Distribution Operators
AGA
APGA
Incident Data
1984 - Jan 2009
4000
3500
3000
2500
ALL OTHER
SYSTEMS
2058
PRESSURE
REGULATOR
18
2000
1500
1000
500
METER SET
ASSEMBLY
623
SERVICE LINE
916
1557
DAMAGE BY UNSPECIFIED
OUTSIDE FORCES
ALL OTHER
103
CAUSES
< 5 psig
597
90
EXCAVATION
DAMAGE
748
960
≥5,<10 psig
30
≥10 psig
840
NATURAL FORCES, 109
0
TARGET SYSTEMS:
SERVICE LINE
METER SET ASSEMBLY
PRESSURE REGULATOR
TARGET CAUSES:
EXCAVATION DAMAGE
NATURAL FORCES
DAMAGE BY OUTSIDE FORCES
TARGET PRESSURE:
≥5 and <10 psig
≥10 psig
870
COMMERCIAL
INDUSTRIAL
MULTIPLE UNIT
RESIDENTIAL
268
SINGLE UNIT
RESIDENTIAL
602
INCIDENT CANDIDATES
FOR EFV MITIGATION
Summary of Industry Large Capacity EFV Issues
 EFVs only work for significant service line breaks
 Larger diameter service lines are less susceptible
to a complete line break
 EFVs can’t distinguish a major leak from a load
 EFVs are not designed to protect from houseline
failures
 The operator does not know the life-cycle load
(50-100 years) at the time of service installation,
making proper service line and EFV sizing
impossible
Summary of Industry Large Capacity EFV Issues
 Multi-family, commercial and industrial customers
have far greater load variability, routinely adding
equipment and associated loads without notifying
the operator
 Commercial establishments are subject to
frequent changes of ownership, product, gas
equipment and associated loads, making
appropriate EFV sizing impossible
Summary of Industry Large Capacity EFV Issues
 Multi-family, commercial and industrial customers
expect a highly reliable gas supply. A false EFV
closure puts the customer out of business, with
associated business losses, until the EFV can be
replaced
 An inadvertent shutoff of commercial or industrial
facilities, such as hospitals, manufacturing or
chemical plants, could create a greater hazard
than the gas leak it was intended to address
 The cost to replace an incorrectly sized EFV may
be $5,000-$50,000 IF the municipality
allows the street to be cut
Industry Large Capacity EFV Recommendation
EFVs on multi-family, commercial and
industrial service lines should be
considered by operators as a risk
management tool and should not be
mandated
Industry Large Capacity EFV Recommendation
Continue the implementation of
effective State excavation damage
prevention programs, including the
nine key elements as defined in the
Pipeline Inspection, Protection,
Enforcement and Safety Act of 2006
PHMSA Large EFV Project Summary / Timeline
 Initial stakeholder meeting- June 23, 2009
 Stakeholder net-meeting- August 25, 2009
 Draft Technical Report-February 19, 2010
 Final Technical Report completed- mid-2010
 PHMSA Operator Survey- year end 2010
 Economic (cost/ benefit) analysis- 2Q 2011
 PHMSA / NAPSR respond to NTSB
PHMSA Large EFV Project Summary
 Operators should continue to install EFVs on any
new or replaced service line serving a single-family
residence after June 1, 2008
 PHMSA will conduct a large EFV operator survey
and cost / benefit study by mid-2011, then respond to
NTSB recommendation
 EFVs have become a Re-authorization issue. NTSB
Chair re-confirmed P-01-2 in testimony on June 24.
In congressional hearings, AGA’s spokesman was
asked to work with other parties to find a workable
path forward. Anticipate EFV language in the 2010
Re-authorization
DIMP - Beyond the Final Rule
Low Stress Transmission Lines Stress level less than or equal to 30 % SMYS at
MAOP
 DIMP Phase 1 Report recommended that integrity
of low-stress transmission lines be managed under
DIMP since these lines behave more like high
pressure distribution lines
 AGA has drafted language for the 2010 Pipeline
Safety Re-authorization that would allow operators
to manage the integrity of low stress transmission
lines under TIMP or DIMP
DIMP - Beyond the Final Rule
In Summary The DIMP Final Rule only created a start point for
your DIMP Program
 There have been significant developments since
the Final DIMP Rule was issued on
December 4, 2009
 In order to successfully comply with DIMP, you
have to go “Beyond the Final Rule”
Questions?