{"operation":"document","citation":"0900006480e836bd","title":"U.S. DOT/PHMSA - Report to Congress","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"Assuring the Integrity of Gas Distribution Pipeline Systems A Report to the Congress May 2005 Submitted by: Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation Table of Contents Executive Summary………………………………………………………………………….1 1. Program Overview………………………………………………………………………..2 2. Regulation of Distribution Systems and the Role of State/Federal Governments………..4 3. The Gas Distribution Safety Baseline…………………………………………………….5 Diversity of Operators………………………………………………………………..5...","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e836bd.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e836bd.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e836bd","source_url":"https://downloads.regulations.gov/PHMSA-RSPA-2004-19854-0074/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nAssuring the Integrity of Gas Distribution Pipeline Systems\nA Report to the Congress\nMay 2005\nSubmitted by:\nOffice of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n\n<<<PAGE 2>>>\n\nTable of Contents\nExecutive Summary………………………………………………………………………….1\n1. Program Overview………………………………………………………………………..2\n2. Regulation of Distribution Systems and the Role of State/Federal Governments………..4\n3. The Gas Distribution Safety Baseline…………………………………………………….5\nDiversity of Operators………………………………………………………………..5\nDiversity of Infrastructure……………………………………………………………7\nExisting Regulations and Practices…………………………………………………..7\nInsights from Incident Data…………………………………………………………..9\nInnovative Practices…………………………………………………………………11\nMonitoring the Effectiveness of Actions……………………………………………11\n4. Evaluation of Applicability of Transmission IM Program and Practices………………..12\nIntegrity Management Elements…………………………………………………….12\nApplicability to Distribution Pipeline Systems……………………………………...12\nIdentifying High Consequence Areas………………………………………..12\na. Hazardous liquid pipelines……………………………….………….12\nb. Gas transmission pipelines…………………………………………..13\nc. Gas distribution pipelines……………………………………………13\nAssessing Pipeline Integrity………………………………………………….14\na. In-line Inspection…………………………………………………….14\nb. Pressure testing………………………………………………………14\nc. Direct Assessment……………………………………………………15\nApplicability of Current IMP Practices………………………………………………17\n5. Principles Guiding the PHMSA Approach………………………………………………..17\n6. Plan and Schedule for Defining and Implementing Distribution Integrity Management\nRequirements…………………………………………………………………………………19\n7. Options Being Considered………………………………………………..……………….21\nSpecific Attention to Excess Flow Valves……………………………………………25\n8. Conclusion………………………………………………………………………………...26\nAttachments\n1. NAPSR State Survey Results -- State Requirements beyond Federal Regulations\nGas Distribution Systems\n2. Summary of Allegro Report – Safety Incidents on Natural Gas Distribution Systems:\nUnderstanding the Hazards, April 2005\n3. NARUC Resolution on Distribution Integrity Management, February 16, 2005\n4. Position of the American Public Gas Association on Distribution Integrity Management\n5. PHMSA/OPS Phase 1 Action Plan\nList of Figures\n1. Distribution systems subject to 49 CFR 192………………………………………………..6\n2. Relationship among Federal Requirements, Standards or Guidelines, and State\nRequirements…………………………………………………………………………………23\n3. Example of High-level Federal Performance Requirements……………………………...24\ni\n\n<<<PAGE 3>>>\n\nAcronyms\nAGA – American Gas Association\nAGF – American Gas Foundation\nAPGA – American Public Gas Association\nCFR – Code of Federal Regulations\nDA – Direct Assessment\nDOT – Department of Transportation\nEIA – Energy Information Administration\nEFV – Excess Flow Valve\nFR – Federal Register\nILI – In-line inspection\nIM – Integrity Management\nIMP – Integrity Management Plan\nLP – Liquid propane\nNAPSR – National Association of Pipeline Safety Representatives\nNARUC – National Association of Regulatory Utility Commissioners\nOPS – Office of Pipeline Safety\nPHMSA – Pipeline and Hazardous Materials Safety Administration\nUSC – United States Code\nii\n\n<<<PAGE 4>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 1\nDistribution Pipeline Systems\nExecutive Summary\nThe FY 2005 Conference Committee on Appropriations asked1 the Department of\nTransportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA)\nOffice of Pipeline Safety (OPS) to submit a report detailing the extent to which integrity\nmanagement plan elements may be applied to gas distribution pipeline systems to enhance\nsafety. “Integrity management” refers to programs that OPS has required of hazardous liquid\nand gas transmission pipeline operators, through rules promulgated within the last five years.\nIntegrity management requirements have not yet been established for gas distribution pipeline\nsystems. The Department of Transportation’s (DOT) Inspector General recommended that\nOPS take this action in testimony before the Congress in 2004.2\nThe principal focus of the existing integrity management regulations for pipelines is to\nidentify the portions of the pipeline system that pose the most risk; to inspect the physical\ncondition of those portions of the pipelines; and to repair any defects that could challenge the\npipeline integrity. The fundamental principles of integrity management require:\nunderstanding the infrastructure and the risks it poses, and then taking actions to address those\nrisks. There are significant differences in the design of gas distribution pipeline systems\ncompared to the pipelines subject to current integrity management regulations. These include\npipe size, operating pressure, materials, and the large number of branches and connections in\ndistribution systems. These design differences significantly limit the applicability of the\ninspection techniques currently in use for those pipelines to distribution pipeline systems.\nThe challenge is to develop appropriate methods to apply the principles of integrity\nmanagement to enhance the safety of distribution pipeline systems, while remaining mindful\nof costs and service disruptions and their potential impact on consumers.\nGas distribution pipelines, those that deliver gas directly to consumers, are almost entirely\nunder the regulatory oversight of state agencies. OPS has implemented a program jointly with\nits state partners and a broad range of stakeholders, to identify means appropriate to\ndistribution pipelines to focus attention on areas that pose the highest risk and to better assure\nthe integrity of those portions of the distribution systems, in other words, integrity\nmanagement.\nThe first phase of the program is to be completed in 2005 and will identify the nature of\nrequirements that might be imposed and any additional guidance or consensus standards that\nmight be needed to assist operators in implementing any integrity management requirements.\nThis phase will include consideration of a multi-faceted set of potential approaches, including\nregulations and guidance, but will also consider a national education program, development of\nnew inspection technologies, and legislative models that states could adopt. The second\nphase, to begin in January 2006, will include development of appropriate requirements by\nOPS and preparation of guidance/standards by appropriate bodies.\n1 House of Representatives Report 108-792, November 20, 2004.\n2 “Progress and Challenges in Improving Pipeline Safety,” Statement of the Honorable Kenneth M. Mead,\nInspector General, Department of Transportation, before the Committee on Energy and Commerce,\nSubcommittee on Energy and Air Quality, U. S. House of Representatives, July 20, 2004.\n\n<<<PAGE 5>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 2\nDistribution Pipeline Systems\n1. Program Overview\nThe DOT Inspector General, in testimony before Congress in July 2004,3 recommended that\nOPS should define an approach for requiring operators of distribution pipeline systems to\nimplement some form of integrity management or enhanced safety program with elements\nsimilar to those required in hazardous liquid and gas transmission pipeline integrity\nmanagement programs. The Appropriations Committee asked OPS “to report to the House\nand Senate Committees on Appropriations by May 1, 2005, detailing the extent to which\nintegrity management plan [IMP] elements may be applied to the natural gas distribution\npipeline industry in order to enhance distribution system safety”.4\nIndustry and government have long been committed to the safe operation of the Nation’s 1.9\nmillion miles of natural gas distribution pipelines. Building on the existing set of\nrequirements, regulators and pipeline operators continue to examine natural gas distribution\npractices to understand the most effective approaches to improving the integrity and safety of\nthese systems.\nDuring the past five years, OPS (as part of PHMSA) has promulgated regulations designed to\nimprove the integrity of liquid and gas transmission pipelines. Together with our State\npartners, PHMSA has undertaken inspection of the programs by which operators are\nimplementing these regulations. Implementation of these regulations has led both to\nimprovements in the operators’ knowledge of their pipelines, and to identification and repair\nof thousands of defects in these pipelines. OPS also regulates distribution pipeline systems.5\nPursuant to agreements among OPS and the States, state inspectors perform most of the\ninspection and enforcement of the pipeline safety regulations on gas distribution systems.\nOPS ensures that State programs provide safety oversight in compliance with the Federal\npipeline safety regulations.\nOPS and our State partners developed a program through which we will thoroughly\nreexamine means for strengthening the safety of distribution pipeline systems. This program\nwill address the three elements of the strategy described by the DOT Inspector General: (a)\nunderstanding the infrastructure; (b) identifying and characterizing the threats; and (c)\ndetermining how best to manage the known risks (prevention, detection and mitigation).\nThese three elements are essentially the same as those underlying the transmission pipeline\nintegrity management regulations. The program will provide the basis for establishing\nintegrity management requirements for distribution pipeline systems. These requirements\nmust be different than those that have been applied to hazardous liquid and gas transmission\n3 Ibid.\n4 House of Representatives Report 108-792, November 20, 2004.\n5 Gas transmission pipelines transport gas from areas where it is produced to areas where it is consumed. These\npipelines are generally steel, of large diameter, operate at high pressures, and traverse long distances, sometimes\nmore than 1,000 miles. Distribution pipeline systems are the network of pipes in communities that provide gas\ndirectly to consumers. They consist of small diameter pipelines, operating at low pressure, and constructed of a\nvariety of materials. Distribution pipelines exist as a network with many branches in short distances (e.g., a\nservice line connection for each house on a city street). The differences between the two types of pipelines can\nlead to a need to use different approaches to assuring safety, as described in this report.\n\n<<<PAGE 6>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 3\nDistribution Pipeline Systems\npipelines, because the models and tools prescribed by those regulations have only very limited\napplicability to distribution pipeline systems.\nThe program presented in this Report was designed to identify opportunities for improving the\nsafety of distribution pipeline systems. Our analysis of the past few years of data identified\nthat in order to address safety threats to distribution pipelines, there are a number of target\naudiences that PHMSA needs to involve in developing strategies to reduce these threats.\nAccordingly, OPS is involving a larger number of key stakeholder groups than contacted in\nthe past, including State and Federal regulators, representatives from the spectrum of\ndistribution operators, interested members of the public, and representatives of our Nation’s\nfire service. These participants are organized into work/study groups that will gather and\nanalyze data to help focus the effort and ultimately identify options for attaining improved\nsafety. In addition, OPS will be posting information on a public web site as the program\nactivities progress, to offer an opportunity for other interested members of the public to\ncomment.\nOPS organized the program in two major phases. During the remainder of 2005 (Phase 1)\nwork/study groups will gather and analyze data, and develop the elements of a safety\nimprovement program. During the following year (Phase 2) OPS and pipeline standards\ndevelopment organizations (if needed) will work to develop requirements, guidelines and\nstandards that will be implemented using some combination of four options favored by a\nconsensus of the stakeholder group.\n• The first option is a high level, risk-based, performance-oriented Federal regulation.\n• The second option is supplemental information through one or more guidelines or\nnational consensus standards describing choices on how the spectrum of distribution\npipeline operators might apply fundamental risk-based principles to achieve the\ndesired improvements. States would then have the opportunity to draw on the\nstandards and guidance to promulgate regulations describing how the unique set of\noperators they regulate should implement improvements satisfying the Federal\nrequirements.\n• Third is a structured nation-wide education program on preventing excavation\ndamage, focused on the new 811 one-call program.\n• The final option is development of innovative safety technologies capable of\nproducing observable safety improvements.\nThe requirements that may result from this program could prove expensive for operators to\nimplement. The view of an executive steering group6 was that it is important to consider all\ncosts related to new efforts to prevent and mitigate distribution line incidents together, in\norder to assure the most cost-effective solution. Thus, the group emphasized the importance\nof evaluating all options for preventing, detecting and mitigating threats to public safety\nconsistently. For example, the group indicated its preference that use of excess flow valves\n(EFVs) as a means of mitigating the impact of severed gas distribution lines should be\n6 See Section 6 for a description of the groups involved in the Action Plan\n\n<<<PAGE 7>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 4\nDistribution Pipeline Systems\nconsidered as part of the overall distribution safety improvement program, rather than being\naddressed in a separate Federal mandate.\n2. Regulation of Distribution Systems and the Role of State/Federal Governments\nThe principal authority for regulating the safety of gas distribution pipeline systems is\nexercised by State governments. Under 49 USC 60105 and 60106, States may exercise\njurisdiction if their pipeline safety programs are certified by the DOT or if they enter into an\nagreement with DOT absent certification. At this time, all States except Alaska and Hawaii\nexercise safety jurisdiction under these provisions. States have a variety of ways in which\nthey can oversee distribution pipeline safety. They can simply mirror the Federal pipeline\nsafety program. They can impose additional requirements, beyond the Federal minimum.\nThey can engage in special oversight programs with individual operators or groups of\noperators. Finally, they can provide incentives for safety improvements, often through their\nrate-setting authority.\nThe Federal government has ultimate responsibility in regulating intrastate distribution\npipeline operators. The Federal standards in 49 CFR Part 192 establish a minimum set of\nsafety requirements that all states must implement. The DOT also collects data concerning\ndistribution system mileage, incidents that occur on systems, their leak repair experience and\nother information about the size, age and material(s) of construction of their distribution\npiping. Initial consideration of an approach to integrity management for distribution pipeline\nsystems will seek to identify changes that could be made in DOT data collection that would\nhelp improve the ability of State and Federal regulators to analyze and more clearly\nunderstand distribution system’s operating experience. The Office of Pipeline Safety will\ndefine further what improvements are needed and will determine if changes to its data\ncollection forms are needed.\nOPS provides funding for the operation of State pipeline safety programs through a grant\nprogram that funds States’ oversight efforts. OPS has, in the past, identified emphasis areas\nfor State focus in their oversight programs. These emphasis areas have included content of\nstate regulations, pursuit of special initiatives, approaches to inspection of operators, and data\ncollection and reporting. OPS can adjust its criteria for state funding grants to assure that\nappropriate emphasis exists in each State’s program.\nOne area for special grant allocation resources is damage prevention – being proactive to\nreduce the likelihood that distribution pipelines will be damaged during excavation work.\n(This is a principal threat to the integrity of distribution pipelines).\nOPS is also engaged in work with state fire marshals, and has included a representative of this\ncommunity in the distribution integrity management program. Representatives of public\ninterest groups are also involved in helping to define the appropriate approaches to assuring\ndistribution system integrity. This inclusiveness demonstrates the willingness of OPS and\nStates to go beyond previous efforts to improve the assurance of distribution pipeline system\nsafety. The OPS will also seek other input through posting documents related to this program\non a web site.\n\n<<<PAGE 8>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 5\nDistribution Pipeline Systems\nIt is appropriate that the principal actions for regulating distribution pipeline safety rest with\nthe States. States need to balance safety and affordability. They need to assure that the\nparticular needs of their citizenry are fulfilled. They also need to assure that the safety\nstandards being applied are appropriate for the unique environment in which gas distribution\noccurs. Distribution pipeline systems are limited in geographic scope. The environment in\nwhich they operate significantly affects the safety issues that they face. Factors such as\nweather (dry/wet, hot/subject to freezing), soil conditions (corrosivity), and the local economy\n(significant construction and excavation activity) can significantly shape the threats affecting\nindividual distribution operators and the actions necessary to address those threats. Proximity\nto gas producing regions also can be important, as natural gas that is distributed near\nproduction areas may be subject to little processing and may contain more contaminants, with\npotential to affect system integrity, than gas that is processed for long-distance transportation.\nStates must have flexibility to deal with their local circumstances. It would be both\nineffective and inefficient, for example, to impose requirements intended to address frost\nheave damage in the desert southwest. Integrity management requirements for distribution\npipeline systems will be structured in a manner that allows States the necessary flexibility in\nimplementation.\n3. The Gas Distribution Safety Baseline\nIn order to know what opportunities there are to enhance distribution pipeline safety, we must\nfirst examine where and how operators are performing today.\nThere is very significant diversity among gas distribution pipeline operators in the United\nStates. The size and technical depth of operators of distribution pipeline systems, the nature\nof the systems they operate, the requirements they must meet, and the practices that they use\nto assure safety all vary widely. An understanding of these differences, and the current\napproach to sharing and using practices that go beyond the regulations, i.e., the “baseline”\nlevel of program management, will be useful in understanding the approach being taken to\nenhance distribution integrity management.\nDiversity of Operators\nOperators of distribution pipeline systems subject to OPS/State safety regulation are of four\ndifferent types:\n• Master meter systems (e.g., trailer parks, individual multi-occupancy buildings)\n• Publicly owned (e.g., town/city/county) municipal utilities\n• Investor-owned utilities\n• Propane gas distribution systems\nThe order within this list represents the prevalence of each type of operator. There are\napproximately 1,000 publicly owned utilities delivering gas to consumers in the United States.\nBy contrast, there are approximately 250 investor-owned utilities engaged in this business.\n\n<<<PAGE 9>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 6\nDistribution Pipeline Systems\nThere are several thousand master meter operators and a few hundred liquid propane (LP) gas\nsystems that are subject to the safety regulations in 49 CFR Part 192.\nFigure 1 - Distribution systems subject to 49 CFR 192\n(Prepared by APGA from E IA data)\n# of systems\n500\n450\n400\n350\n300\n250\n200\n150\n100\n50\n0\n438\n354\nMunicipal\nInvestor-owned\n96\n59 69\n50\n35\n20\n6 0\n10\n< 100 100-1000 1000-10000 10000-100000 100000-1 million > 1 million\n# of customers (from EIA Form 176)\nNote: EIA does not maintain data on the number of customers served by master meter systems or liquid propane\n(LP) gas systems. There are several thousand master meter operators, the vast majority of which serve less than\n100 customers. There are approximately 200 LP gas systems most of which also serve less than 100 customers.\nWithin each of these groups, the size of individual operators also varies widely, as shown in\nFigure 1. Publicly-owned utilities tend to be smaller, with a majority serving less than 1,000\ncustomers. In general, investor-owned utilities tend to be larger, with slightly over 100\ncompanies serving more than 100,000 customers each. There are examples, though, of\npublicly owned utilities serving 100,000 customers and of investor-owned companies serving\nless than 1,000. The variability makes it difficult to generalize regarding these groups. The\nparticular circumstances of each operator must be taken into account.\nMaster meter operators are businesses such as apartment complexes, or mobile home or trailer\nparks, or are government entities like housing authorities and universities that receive gas\nfrom an outside supplier and distribute it via pipelines located within their facilities. These\noperators are generally small, with a large majority serving fewer than 100 customers.\nDistribution of gas, or operation of the distribution systems, is not their principal business.\nPropane system operators subject to pipeline regulation are also small. Propane used in\nindividual installations, such as a rural farm with its own propane tank, is not subject to\nregulation as a pipeline system. Propane systems become subject to regulation when they\ndistribute gas, by pipeline, to 10 or more customers. The large majority of these systems\nlikely serve fewer than 100 customers.\n\n<<<PAGE 10>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 7\nDistribution Pipeline Systems\nDiversity of Infrastructure\nThe pipeline systems operated by these operators are also subject to much variation.\nNatural gas has been distributed by pipeline in some areas for over a hundred years. Pipeline\nsystems in these areas were originally small, serving a few customers. These systems merged\nas larger distribution companies were formed. The materials in use in some of these systems\nreflect older (e.g., cast iron, copper, bare steel) as well as newer (e.g., polyethylene plastic and\ncathodically protected coated steel) technology.\nIn other areas, distribution of natural gas by pipeline is a relatively new phenomenon. In\nsome rural areas, for example, gas may not have been available until a transmission pipeline\nwas routed into the vicinity. Then, municipalities or distribution companies may have created\na distribution system to bring natural gas service to customers for whom it was previously\nunavailable. Systems of this nature tend to be relatively uniform in age and type of materials,\nbut the threats to integrity (such as electrical interference from other buried substructures and\nlocalized flooding or vehicular traffic patterns) may still vary from one location to another.\nAdditional diversity will likely be introduced as systems age, new customers are added, and\nportions of the original systems are replaced.\nIndividual master meter systems and propane systems tend to be relatively uniform due to\ntheir small size and limited geographical extent.\nExisting Regulations and Practices\nThe Federal pipeline safety standards in 49 CFR Part 192 provide a common base of\nrequirements applicable to distribution pipeline systems. These standards address design,\nconstruction and operation of pipeline systems as well as requirements affecting inspection,\nmaintenance, repair and testing and also qualification of pipeline operations personnel. States\nare required to adopt these standards as one of the criteria for certifying their pipeline safety\nprograms or for entering into an agreement with OPS to exercise safety jurisdiction. States\ncan, and do, impose additional requirements where appropriate.\nThe National Association of Pipeline Safety Representatives (NAPSR) is an organization\nconsisting of the senior regulatory program manager from each State that exercises pipeline\nsafety jurisdiction. NAPSR recently conducted a survey of its members to identify the extent\nof additional State requirements that go beyond Part 192. The survey identified that most\nStates impose some additional requirements. A majority impose stricter criteria for reporting\nincidents and/or requires that operators notify the regulator of construction or testing that\nwould provide an opportunity for the regulator to examine the pipeline and observe safety-\nsignificant work. These type of requirements reflect the close oversight relationship that\nexists between most state regulatory programs and the operators they regulate. State\nregulators generally interact routinely with operators under their jurisdiction, and therefore\nknow their systems and personnel. States are actively engaged, on a daily basis, in overseeing\nsafe operations. Additionally, approximately 25 percent of the States impose requirements for\nleak surveys beyond those required in Part 192.\n\n<<<PAGE 11>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 8\nDistribution Pipeline Systems\nThe NAPSR survey also identified that approximately 65 percent of States have a program to\nreplace some types of distribution piping. This may include cast iron pipe, uncoated and\nunprotected steel pipe, or certain types of plastic pipe that have been found to be subject to\ndeterioration in service. The replacement programs vary in scope. In some cases, they\ninvolve all (or nearly all) of the operators in a State. In other cases, they may involve\nindividual operators and may have been initiated as a result of an incident or event that\nhighlighted problems associated with the aging material.\nA summary of the NAPSR survey results is included as Attachment 1 to this report.\nIn addition to the NAPSR survey, OPS contacted several larger investor-owned utilities to\nobtain information about their safety practices that exceed minimum regulatory requirements.\nThe operators surveyed, all of which serve mid- to large-sized cities, all reported that they use\nrisk evaluation to help direct work on their pipelines. This supports a conclusion of the\nAmerican Gas Foundation (AGF) that 82% of companies they surveyed use risk control\npractices.7 Use of risk models is not currently required of distribution system operators.\nNeither OPS nor States have audited these models or their application. We therefore cannot\ncomment yet on the thoroughness of the approaches used, but note with satisfaction that the\nconcept of using an estimate of risk to manage safety activities is becoming widely prevalent.\nOPS’ discussions also identified that the larger operators all had pipe management programs\nthat included replacing portions of their system: where problems had been experienced\nidentifying materials susceptible to failure; where certain construction practices potentially\nleading to problems may have been used; that include their older pipelines; or based on\nestimated risk. Again, this reinforces the AGF conclusion that 65% of surveyed companies\nhad replacement programs.8 (It should be noted that replacement of pipe in highly built-up\nurban areas can be difficult due to the number and complexity of buried infrastructure\nfacilities and the difficulty of working in the urban environment.)\nThe operators contacted by OPS also perform leak surveys more frequently, based on unique\noperating conditions, than would be required by regulations and implement special practices\nto reduce third party damage.\nMost of the operators contacted by OPS also reported that they have elected to install excess\nflow valves (EFV) for new and replacement services, which goes beyond the regulatory\nrequirement that customers be apprised of the availability of EFVs and that they be installed if\nthe customer agrees to pay for them.\nThe most prevalent safety practice followed by distribution system operators that is not\nrequired by Part 192 is membership in damage prevention programs, most often referred to as\n“one-call” programs. The AGF reports that over 95 percent of operators belong to such\n7 American Gas Foundation, “Safety Performance and Integrity of the Natural Gas Distribution Infrastructure”,\nJanuary 2005, p. 5-11.\n8 Ibid, p. 5-13.\n\n<<<PAGE 12>>>\n\nA Report to the Congress: Assuring the Integrity of Gas 9\nDistribution Pipeline Systems\nprograms.9 Most states require gas utilities to belong to one-call programs. The breadth of\nparticipation in these activities provides a basis to presume that excavation damage incidents\ncan be reduced. However, unfortunately, these incidents continue to occur. They are\nundoubtedly less prevalent than they would be in the absence of one-call programs, but they\nstill represent a threat to distribution pipeline systems. This program will specifically include\na review of industry practices and other approaches to prevent or reduce damage to identify\nways in which their effectiveness can be improved.\nInsights from Incident Data\nThe principal source of information available about distribution pipeline system safety and\nintegrity is the data resulting from incident reports submitted to OPS. These reports are filed\nby operators, pursuant to 49 CFR 191.9, and include events occurring on jurisdictional\npipelines that involve either: 1) a death or personal injury necessitating in-patient\nhospitalization; 2) estimated property damage, including cost of gas lost, of the operator or\nothers, or both, of $50,000 or more; or 3) events that are significant, in the judgment of the\noperator, even if neither of the other criteria is met or exceeded.\nOPS changed its incident report form in 2004 to require that the cause of incidents be reported\nmore precisely. All incidents reported prior to that time were attributed by the reporting\noperator to one of five major causes, one of which was “other.” Using the revised forms,\noperators identify one of seven major causes, which are further subdivided into 25 second-\nlevel causes. This change is intended to improve our understanding of the factors that result\nin gas pipeline incidents.\nThe set of incident data submitted by operators represents significant problems that occur on\nthe pipeline. It does not include all events involving or exacerbated by natural gas from\ndistribution pipeline systems. For example, problems with an appliance in a customer’s home\ncould result in an accumulation of gas, an explosion, and fire, potentially resulting in injury or\ndeath. Although the media may report such events as gas pipeline incidents, they are not.\nOPS has no regulatory authority over customer-owned piping or gas appliances, and operators\nare not required to report such events to OPS. Customer piping within homes and businesses\nis regulated by local building codes, often based on the National Fuel Gas Code or other\nmodel codes.\nThere have been two recent studies that considered recent distribution incident experience.\nOne was conducted by the AGF, under the oversight of a committee formed of representatives\nfrom AGF members and state pipeline safety regulators. The results of this study were\nreported in “Safety Performance and Integrity of the Natural Gas Distribution Infrastructure,”\npublished by AGF in January 2005. The other was performed by Allegro Energy Consulting,\nin late 2004, under contract to OPS.\nThe AGF study covered the period from 1990 to 2002. During that period, AGF found a\nstatistically significant downward trend in “serious” incidents, defined as those involving a\n9 Ibid, p. 5-12.\n\n<<<PAGE 13>>>\n\nA Report to the Congress: Assuring the Integrity of Gas Distribution Pipeline Systems\n10\ndeath or injury. (AGF chose to focus on these incidents because the reporting criteria are not\nas subjective as “significant to the operator” nor do local economic factors or inflation affect\nreporting of an event wherever or whenever it occurs.) The AGF concluded there were\napproximately 1.6 serious incidents per 100,000 miles of distribution pipeline during 2002.\nThe AGF study identified that nearly half of the serious incidents occurring during the study\nperiod were a result of outside force damage. The only other cause category contributing to\nmore than 10 percent of serious incidents was “other” which was responsible for almost 27\npercent.\nThe Allegro study re-evaluated five years of incident report data (1999-2003) to re-classify\nthem to the new cause categories. This was accomplished by reviewing the narrative\ndescription of the incident that the operator provided when submitting the original report.\nAllegro considered 634 incidents reported in the five-year period. One third of them involved\ndeath or injury, i.e., would have been considered “serious” incidents by the AGF study.\nNearly one half were reported due to the cost of damages alone. Six percent of the incidents\napparently did not meet any of the reporting criteria, but they were still retained in the Allegro\nanalysis.\nAllegro’s re-classification was successful in reducing the number of incidents for which the\ncause could not be attributed from the 27 percent noted in the AGF study to 12 percent.\nAllegro further found that a large majority of the incidents (67%) were caused by outside\nforce damage. The new cause categories permitted Allegro to break the outside force damage\ncategory down into several components. Thirty-eight percent of the incidents were caused by\nexcavation and mechanical damage (the vast majority caused by third parties), but 29 percent\nwere caused by other sources of outside force. This new category included two major\ncomponents: “fire first” and vehicle damage, each representing 11 percent of the total number\nof incidents.\nThe fire first events represent incidents in which a building was on fire and the operator\nresponded, but the fire was not caused by a gas leak. In many cases, the gas supply system in\nthe building is compromised or damaged by the fire and contributes to its intensity until the\ngas can be shut off. Fire first incidents are not caused by problems in the gas distribution\nsystem and cannot be addressed in a distribution integrity management program.\nThe vehicle-related events represent incidents in which a vehicle impacts a portion of the\npipeline system, often the above-ground meter assembly. The accidents resulted from\nmultiple causes, including drivers operating their vehicles while intoxicated and unattended\nvehicles rolling into the pipeline system. Allegro found that this category of incidents, while\nrepresenting 11 percent of all incidents, involved 25 percent of the fatal incidents over the\nperiod studied. Thus, these data tell us that 1 out of 4 of the fatal incidents during this period\ncould not have been prevented by any preventive action taken on the pipeline. Reducing the\nnumber of these incidents is likely to require actions that affect persons not under the\nregulatory jurisdiction of OPS or State pipeline regulatory authorities, i.e., vehicle operators.\nA summary of the Allegro report is included as Attachment 2.\n\n<<<PAGE 14>>>\n\nA Report to the Congress: Assuring the Integrity of Gas Distribution Pipeline Systems\n11\nInnovative Practices\nThe American Gas Association (AGA) each year sponsors groups from among its members to\nidentify innovative practices that they employ to improve operational performance and safety.\nThese groups typically evaluate approximately five topic areas (e.g., damage prevention, main\nand service replacement, system reliability). In each area, practices of member companies are\nshared, innovative practices are identified, and the information is exchanged with participants\nat a roundtable forum. Detailed information is available only to companies that have\nparticipated in the groups.\nThese forums serve a useful purpose and can contribute to expanding the understanding and\napplication of innovative practices. This expansion can occur among participants, which are\ngenerally the larger, investor-owned companies. The results of these efforts are not available\nto operators that do not directly participate in the program, particularly publicly-owned\noperators that are not usually members of AGA.\nOPS believes that these activities have a positive impact on the reduction of incidents\ndisproportionate to the percentage of operators that participate. There are two reasons for\nbelieving this: the large-operator participants operate a much larger percentage of the total\ndistribution pipeline mileage than their numbers might suggest; and smaller operators,\nparticularly those with only a few persons on staff and a limited amount of pipeline mileage,\ngenerally have much better detailed knowledge of their systems and the issues that affect\nthem.\nNevertheless, the impact of these activities is limited. Participation is not available to\nmunicipal operators who are not AGA members and often lack the staff resources necessary\nto become involved in this kind of outside activity. Also, not all AGA members participate in\nthese activities.\nMonitoring the Effectiveness of Actions\nIt is important that the effectiveness of whatever actions are taken to improve distribution\npipeline safety be monitored. The ultimate measure of distribution pipeline system safety is\nthe number of deaths and injuries and the amount of property damage caused by incidents on\ndistribution pipeline systems. Fortunately, however, incidents occur relatively infrequently.\nOther interim measures are needed to evaluate the effectiveness of any new integrity\nmanagement requirements implemented for distribution pipeline systems. An interim\nmeasure might be how any new regulatory initiatives impact system operators (e.g., the\nnumber of assessments or repairs that have been conducted is an interim measure of the\neffectiveness of the hazardous liquid and gas transmission integrity management rules). The\nprogram described in this report includes development of a way to measure these impacts and\nto develop a baseline from which improvements can be measured.\n\n<<<PAGE 15>>>\n\nA Report to the Congress: Assuring the Integrity of Gas Distribution Pipeline Systems\n12\n4. Evaluation of Applicability of Transmission IM Program and Practices\nOPS promulgated regulations in recent years requiring that pipeline operators (other than\ndistribution pipeline operators) implement integrity management programs. These regulations\napply to operators of hazardous liquid pipelines (49 CFR 195.452, published at 65 FR 75378\nand 67 FR 2136) and to operators of gas transmission pipelines (49 CFR 192, Subpart O,\npublished at 68 FR 69778). It is reasonable to ask why the same techniques used in these\nregulations cannot simply be applied to gas distribution pipeline systems. Both regulations\nset requirements for making best use of information to set safety priorities and to perform\ncontinuous evaluations.\nIntegrity Management Elements\nThe integrity management regulations for hazardous liquid and gas transmission pipelines are\nsimilar. Both require that operators identify segments of their pipeline where an incident\ncould create high consequences. Both require that operators implem","truncated":true,"body_characters":118915}