2010 western regional gas conference dimp- beyond the final rule august 24, 2010 tempe, az bruce l....

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


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


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



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


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


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)


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


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


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

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Number of Incidents, 99-03

3%

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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


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)


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


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!


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 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


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:


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


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

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 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


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


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


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?Questions?

2010 western regional gas conference dimp- beyond the final rule august 24, 2010 tempe, az bruce l....

Documents

dimp final rule

final dimp rule

dimp program192

dimp nopr

final rule192

final ruleaugust

final ruledimp

effective leaks program