2010 western regional gas conference dimp- beyond the final rule august 24, 2010 tempe, az bruce l....
TRANSCRIPT
2010 Western Regional Gas Conference
DIMP- Beyond the Final Rule
August 24, 2010Tempe, AZ
Bruce L. Paskett P.E. Principal Compliance Engineer
NW Natural
NW Natural Company Background
Company founded in 1859Operate in Oregon and SW WashingtonServe approximately 670,000 residential,
commercial and industrial customersDesigned, constructed, own and operate 603
miles of transmission main and 21,000 miles of distribution mains and servicesCompany 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
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
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 Definition-An 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
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) 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
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
DIMP - Beyond the Final Rule
AllegroEnergy Consulting
© Cheryl J. Trench, 2004
And Now, the New “Small Buckets” And Now, the New “Small Buckets” (i.e., 2(i.e., 2ndnd--Level Causes): Hazards, ActorsLevel Causes): Hazards, Actors
0
50
100
150
200
250
Corrosion Nat'lForces
Excav/Mech
Dam'g
OtherOutside
Mat'l/Weld
Equip/OperError
Other
ThirdParty
FireFirstOper
Vehicle
Misc.Oper
Number of Incidents, 99-03
3%
7%
38%
29%
5% 7%
12%
Unk.
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 Guidance- Frequently 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 - Beyond the Final Rule
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 - Excess Flow Valve (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”.
DIMP - EFV Requirements
EFV Installation Location
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……….
DIMP - EFV Requirements
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 Recommendations-
The 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.
NTSB Recommendation P-01-2
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.
Beyond DIMP - Large Volume EFV
PHMSA soliciting input from following stakeholders:
PHMSA Large EFV Team
Organizations Represented
1557 960 870
1984 - Jan 2009
Incident Data
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
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”
DIMP - Beyond the Final Rule
Questions?Questions?