# U.S. DOT/PHMSA - June 2005 Report to Congress on Pipeline Integrity - **operation:** document - **citation:** 0900006480e84144 - **title:** U.S. DOT/PHMSA - June 2005 Report to Congress on Pipeline Integrity - **source type:** rulemaking - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** current - **official:** true - **published on:** Not available - **effective on:** Not available - **summary:** The report explains why existing integrity management techniques for hazardous liquid and gas transmission pipelines have limited applicability to gas distribution systems, outlines a two-phase PHMSA/OPS program (Phase 1 in 2005 to gather data and identify options; Phase 2 in 2006 to develop requirements/guidance), and presents options under consideration (including a high-level Federal rule plus guidance, a national education program, and R&D). It highlights the diversity of distribution operators and infrastructure, incident data findings (notably excavation/outside force damage), practical limits of inspection methods (in-line inspection, pressure testing, Direct Assessment), and consideration of excess flow valves as a mitigation option. The report’s scope is a technical and programmatic assessment to inform possible requirements; it notes limitations in applicability of transmission - **machine formats:** - **json:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e84144.json - **markdown:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e84144.md - **app url:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e84144 - **source url:** https://downloads.regulations.gov/PHMSA-RSPA-2004-18938-0036/attachment_1.pdf **body:** <<>> U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration JUN 20 2005 The Honorable Thad Cochran Chairman Committee on Appropriations United States Senate Washington, DC 20510 Dear Mr. Chairman: Enclosed is a report to the Congress detailing the extent to which pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Ranking Member of the Senate Committee on Appropriations; the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman and Ranking Member of the House Committee on Appropriations; and the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at 202) 366-4831. Sincerely yours, Ma quar Stacey L. Gerar Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUN 20 2005 The Honorable Robert C. Byrd Ranking Member Committee on Appropriations United States Senate Washington, DC 20510 Dear Senator Byrd: Enclosed is a report to the Congress detailing the extent to which Pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman of the Senate Committee on Appropriations; the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman and Ranking Member of the House Committee on Appropriations; and the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUN 2 0 2005 The Honorable Christopher Bond Chairman Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies Committee on Appropriations United States Senate Washington, DC 20510 Dear Mr. Chairman: Enclosed is a report to the Congress detailing the extent to pipeline which integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman and Ranking Member of the Senate Committee on Appropriations; the Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman and Ranking Member of the House Committee on Appropriations; and the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, A fund tacey L. Gerat Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety JUN 2 0 2005 The Honorable Patty Murray Ranking Member Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies Committee on Appropriations United States Senate Washington, DC 20510 Dear Senator Murray: Enclosed is a report to the Congress detailing the extent to which pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman and Ranking Member of the Senate Committee on Appropriations; the Chairman of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman and Ranking Member of the House Committee on Appropriations; and the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, stacey L. Gerar Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUN 20 2005 The Honorable Jerry Lewis Chairman Committee on Appropriations United States House of Representatives Washington, DC 20515 Dear Mr. Chairman: Enclosed is a report to the Congress detailing the extent to which pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman and Ranking Member of the Senate Committee on Appropriations; the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Ranking Member of the House Committee on Appropriations; and the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, A quack Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUN 20 2005 The Honorable David R. Obey Ranking Member Committee on Appropriations United States House of Representatives Washington, DC 20515 Dear Congressman Obey: Enclosed is a report to the Congress detailing the extent to which pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman and Ranking Member of the Senate Committee on Appropriations; the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman of the House Committee on Appropriations; and the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, Na sash Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUN 20 2005 The Honorable Joe Knollenberg Chairman Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies Committee on Appropriations United States House of Representatives Washington, DC 20515 Dear Mr. Chairman: Enclosed is a report to the Congress detailing the extent to which pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This report responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman and Ranking Member of the Senate Committee on Appropriations; the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman and Ranking Member of the House Committee on Appropriations; and the Ranking Member of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, Afraid Stacey L. Gera Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety JUN 20 2005 The Honorable John W. Olver Ranking Member Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies Committee on Appropriations United States House of Representatives Washington, DC 20515 Dear Congressman Olver: Enclosed is a report to the Congress detailing the extent to which pipeline integrity management plan elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety. This responds to U.S. House of Representatives Report 108-792, accompanying the U.S. Department of Transportation and Related Agencies Appropriations Act for fiscal year 2005. An identical letter and report have been sent to the Chairman and Ranking Member of the Senate Committee on Appropriations; the Chairman and Ranking Member of the Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, Senate Committee on Appropriations; the Chairman and Ranking Member of the House Committee on Appropriations; and the Chairman of the Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia, and Independent Agencies, House Committee on Appropriations. If we can be of further assistance, please contact me or James Wiggins, Office of Governmental, International and Public Affairs, at (202) 366-4831. Sincerely yours, Acting Assistant Administrator/Chief Safety Officer Enclosure <<>> 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 Diversity of Infrastructure……………………………………………………………7 Existing Regulations and Practices…………………………………………………..7 Insights from Incident Data…………………………………………………………..9 Innovative Practices…………………………………………………………………11 Monitoring the Effectiveness of Actions……………………………………………11 4. Evaluation of Applicability of Transmission IM Program and Practices………………..12 Integrity Management Elements…………………………………………………….12 Applicability to Distribution Pipeline Systems……………………………………...12 Identifying High Consequence Areas………………………………………..12 a. Hazardous liquid pipelines……………………………….………….12 b. Gas transmission pipelines…………………………………………..13 c. Gas distribution pipelines……………………………………………13 Assessing Pipeline Integrity………………………………………………….14 a. In-line Inspection…………………………………………………….14 b. Pressure testing………………………………………………………14 c. Direct Assessment……………………………………………………15 Applicability of Current IMP Practices………………………………………………17 5. Principles Guiding the PHMSA Approach………………………………………………..17 6. Plan and Schedule for Defining and Implementing Distribution Integrity Management Requirements…………………………………………………………………………………19 7. Options Being Considered………………………………………………..……………….21 Specific Attention to Excess Flow Valves……………………………………………25 8. Conclusion………………………………………………………………………………...26 Attachments 1. NAPSR State Survey Results -- State Requirements beyond Federal Regulations Gas Distribution Systems 2. Summary of Allegro Report – Safety Incidents on Natural Gas Distribution Systems: Understanding the Hazards, April 2005 3. NARUC Resolution on Distribution Integrity Management, February 16, 2005 4. Position of the American Public Gas Association on Distribution Integrity Management 5. PHMSA/OPS Phase 1 Action Plan List of Figures 1. Distribution systems subject to 49 CFR 192………………………………………………..6 2. Relationship among Federal Requirements, Standards or Guidelines, and State Requirements…………………………………………………………………………………23 3. Example of High-level Federal Performance Requirements……………………………...24 i <<>> Acronyms AGA – American Gas Association AGF – American Gas Foundation APGA – American Public Gas Association CFR – Code of Federal Regulations DA – Direct Assessment DOT – Department of Transportation EIA – Energy Information Administration EFV – Excess Flow Valve FR – Federal Register ILI – In-line inspection IM – Integrity Management IMP – Integrity Management Plan LP – Liquid propane NAPSR – National Association of Pipeline Safety Representatives NARUC – National Association of Regulatory Utility Commissioners OPS – Office of Pipeline Safety PHMSA – Pipeline and Hazardous Materials Safety Administration USC – United States Code ii <<>> A Report to the Congress: Assuring the Integrity of Gas 1 Distribution Pipeline Systems Executive Summary The FY 2005 Conference Committee on Appropriations asked1 the Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) Office of Pipeline Safety (OPS) to submit a report detailing the extent to which integrity management plan elements may be applied to gas distribution pipeline systems to enhance safety. “Integrity management” refers to programs that OPS has required of hazardous liquid and gas transmission pipeline operators, through rules promulgated within the last five years. Integrity management requirements have not yet been established for gas distribution pipeline systems. The Department of Transportation’s (DOT) Inspector General recommended that OPS take this action in testimony before the Congress in 2004.2 The principal focus of the existing integrity management regulations for pipelines is to identify the portions of the pipeline system that pose the most risk; to inspect the physical condition of those portions of the pipelines; and to repair any defects that could challenge the pipeline integrity. The fundamental principles of integrity management require: understanding the infrastructure and the risks it poses, and then taking actions to address those risks. There are significant differences in the design of gas distribution pipeline systems compared to the pipelines subject to current integrity management regulations. These include pipe size, operating pressure, materials, and the large number of branches and connections in distribution systems. These design differences significantly limit the applicability of the inspection techniques currently in use for those pipelines to distribution pipeline systems. The challenge is to develop appropriate methods to apply the principles of integrity management to enhance the safety of distribution pipeline systems, while remaining mindful of costs and service disruptions and their potential impact on consumers. Gas distribution pipelines, those that deliver gas directly to consumers, are almost entirely under the regulatory oversight of state agencies. OPS has implemented a program jointly with its state partners and a broad range of stakeholders, to identify means appropriate to distribution pipelines to focus attention on areas that pose the highest risk and to better assure the integrity of those portions of the distribution systems, in other words, integrity management. The first phase of the program is to be completed in 2005 and will identify the nature of requirements that might be imposed and any additional guidance or consensus standards that might be needed to assist operators in implementing any integrity management requirements. This phase will include consideration of a multi-faceted set of potential approaches, including regulations and guidance, but will also consider a national education program, development of new inspection technologies, and legislative models that states could adopt. The second phase, to begin in January 2006, will include development of appropriate requirements by OPS and preparation of guidance/standards by appropriate bodies. 1 House of Representatives Report 108-792, November 20, 2004. 2 “Progress and Challenges in Improving Pipeline Safety,” Statement of the Honorable Kenneth M. Mead, Inspector General, Department of Transportation, before the Committee on Energy and Commerce, Subcommittee on Energy and Air Quality, U. S. House of Representatives, July 20, 2004. <<>> A Report to the Congress: Assuring the Integrity of Gas 2 Distribution Pipeline Systems 1. Program Overview The DOT Inspector General, in testimony before Congress in July 2004,3 recommended that OPS should define an approach for requiring operators of distribution pipeline systems to implement some form of integrity management or enhanced safety program with elements similar to those required in hazardous liquid and gas transmission pipeline integrity management programs. The Appropriations Committee asked OPS “to report to the House and Senate Committees on Appropriations by May 1, 2005, detailing the extent to which integrity management plan [IMP] elements may be applied to the natural gas distribution pipeline industry in order to enhance distribution system safety”.4 Industry and government have long been committed to the safe operation of the Nation’s 1.9 million miles of natural gas distribution pipelines. Building on the existing set of requirements, regulators and pipeline operators continue to examine natural gas distribution practices to understand the most effective approaches to improving the integrity and safety of these systems. During the past five years, OPS (as part of PHMSA) has promulgated regulations designed to improve the integrity of liquid and gas transmission pipelines. Together with our State partners, PHMSA has undertaken inspection of the programs by which operators are implementing these regulations. Implementation of these regulations has led both to improvements in the operators’ knowledge of their pipelines, and to identification and repair of thousands of defects in these pipelines. OPS also regulates distribution pipeline systems.5 Pursuant to agreements among OPS and the States, state inspectors perform most of the inspection and enforcement of the pipeline safety regulations on gas distribution systems. OPS ensures that State programs provide safety oversight in compliance with the Federal pipeline safety regulations. OPS and our State partners developed a program through which we will thoroughly reexamine means for strengthening the safety of distribution pipeline systems. This program will address the three elements of the strategy described by the DOT Inspector General: (a) understanding the infrastructure; (b) identifying and characterizing the threats; and (c) determining how best to manage the known risks (prevention, detection and mitigation). These three elements are essentially the same as those underlying the transmission pipeline integrity management regulations. The program will provide the basis for establishing integrity management requirements for distribution pipeline systems. These requirements must be different than those that have been applied to hazardous liquid and gas transmission 3 Ibid. 4 House of Representatives Report 108-792, November 20, 2004. 5 Gas transmission pipelines transport gas from areas where it is produced to areas where it is consumed. These pipelines are generally steel, of large diameter, operate at high pressures, and traverse long distances, sometimes more than 1,000 miles. Distribution pipeline systems are the network of pipes in communities that provide gas directly to consumers. They consist of small diameter pipelines, operating at low pressure, and constructed of a variety of materials. Distribution pipelines exist as a network with many branches in short distances (e.g., a service line connection for each house on a city street). The differences between the two types of pipelines can lead to a need to use different approaches to assuring safety, as described in this report. <<>> A Report to the Congress: Assuring the Integrity of Gas 3 Distribution Pipeline Systems pipelines, because the models and tools prescribed by those regulations have only very limited applicability to distribution pipeline systems. The program presented in this Report was designed to identify opportunities for improving the safety of distribution pipeline systems. Our analysis of the past few years of data identified that in order to address safety threats to distribution pipelines, there are a number of target audiences that PHMSA needs to involve in developing strategies to reduce these threats. Accordingly, OPS is involving a larger number of key stakeholder groups than contacted in the past, including State and Federal regulators, representatives from the spectrum of distribution operators, interested members of the public, and representatives of our Nation’s fire service. These participants are organized into work/study groups that will gather and analyze data to help focus the effort and ultimately identify options for attaining improved safety. In addition, OPS will be posting information on a public web site as the program activities progress, to offer an opportunity for other interested members of the public to comment. OPS organized the program in two major phases. During the remainder of 2005 (Phase 1) work/study groups will gather and analyze data, and develop the elements of a safety improvement program. During the following year (Phase 2) OPS and pipeline standards development organizations (if needed) will work to develop requirements, guidelines and standards that will be implemented using some combination of four options favored by a consensus of the stakeholder group. • The first option is a high level, risk-based, performance-oriented Federal regulation. • The second option is supplemental information through one or more guidelines or national consensus standards describing choices on how the spectrum of distribution pipeline operators might apply fundamental risk-based principles to achieve the desired improvements. States would then have the opportunity to draw on the standards and guidance to promulgate regulations describing how the unique set of operators they regulate should implement improvements satisfying the Federal requirements. • Third is a structured nation-wide education program on preventing excavation damage, focused on the new 811 one-call program. • The final option is development of innovative safety technologies capable of producing observable safety improvements. The requirements that may result from this program could prove expensive for operators to implement. The view of an executive steering group6 was that it is important to consider all costs related to new efforts to prevent and mitigate distribution line incidents together, in order to assure the most cost-effective solution. Thus, the group emphasized the importance of evaluating all options for preventing, detecting and mitigating threats to public safety consistently. For example, the group indicated its preference that use of excess flow valves (EFVs) as a means of mitigating the impact of severed gas distribution lines should be 6 See Section 6 for a description of the groups involved in the Action Plan <<>> A Report to the Congress: Assuring the Integrity of Gas 4 Distribution Pipeline Systems considered as part of the overall distribution safety improvement program, rather than being addressed in a separate Federal mandate. 2. Regulation of Distribution Systems and the Role of State/Federal Governments The principal authority for regulating the safety of gas distribution pipeline systems is exercised by State governments. Under 49 USC 60105 and 60106, States may exercise jurisdiction if their pipeline safety programs are certified by the DOT or if they enter into an agreement with DOT absent certification. At this time, all States except Alaska and Hawaii exercise safety jurisdiction under these provisions. States have a variety of ways in which they can oversee distribution pipeline safety. They can simply mirror the Federal pipeline safety program. They can impose additional requirements, beyond the Federal minimum. They can engage in special oversight programs with individual operators or groups of operators. Finally, they can provide incentives for safety improvements, often through their rate-setting authority. The Federal government has ultimate responsibility in regulating intrastate distribution pipeline operators. The Federal standards in 49 CFR Part 192 establish a minimum set of safety requirements that all states must implement. The DOT also collects data concerning distribution system mileage, incidents that occur on systems, their leak repair experience and other information about the size, age and material(s) of construction of their distribution piping. Initial consideration of an approach to integrity management for distribution pipeline systems will seek to identify changes that could be made in DOT data collection that would help improve the ability of State and Federal regulators to analyze and more clearly understand distribution system’s operating experience. The Office of Pipeline Safety will define further what improvements are needed and will determine if changes to its data collection forms are needed. OPS provides funding for the operation of State pipeline safety programs through a grant program that funds States’ oversight efforts. OPS has, in the past, identified emphasis areas for State focus in their oversight programs. These emphasis areas have included content of state regulations, pursuit of special initiatives, approaches to inspection of operators, and data collection and reporting. OPS can adjust its criteria for state funding grants to assure that appropriate emphasis exists in each State’s program. One area for special grant allocation resources is damage prevention – being proactive to reduce the likelihood that distribution pipelines will be damaged during excavation work. (This is a principal threat to the integrity of distribution pipelines). OPS is also engaged in work with state fire marshals, and has included a representative of this community in the distribution integrity management program. Representatives of public interest groups are also involved in helping to define the appropriate approaches to assuring distribution system integrity. This inclusiveness demonstrates the willingness of OPS and States to go beyond previous efforts to improve the assurance of distribution pipeline system safety. The OPS will also seek other input through posting documents related to this program on a web site. <<>> A Report to the Congress: Assuring the Integrity of Gas 5 Distribution Pipeline Systems It is appropriate that the principal actions for regulating distribution pipeline safety rest with the States. States need to balance safety and affordability. They need to assure that the particular needs of their citizenry are fulfilled. They also need to assure that the safety standards being applied are appropriate for the unique environment in which gas distribution occurs. Distribution pipeline systems are limited in geographic scope. The environment in which they operate significantly affects the safety issues that they face. Factors such as weather (dry/wet, hot/subject to freezing), soil conditions (corrosivity), and the local economy (significant construction and excavation activity) can significantly shape the threats affecting individual distribution operators and the actions necessary to address those threats. Proximity to gas producing regions also can be important, as natural gas that is distributed near production areas may be subject to little processing and may contain more contaminants, with potential to affect system integrity, than gas that is processed for long-distance transportation. States must have flexibility to deal with their local circumstances. It would be both ineffective and inefficient, for example, to impose requirements intended to address frost heave damage in the desert southwest. Integrity management requirements for distribution pipeline systems will be structured in a manner that allows States the necessary flexibility in implementation. 3. The Gas Distribution Safety Baseline In order to know what opportunities there are to enhance distribution pipeline safety, we must first examine where and how operators are performing today. There is very significant diversity among gas distribution pipeline operators in the United States. The size and technical depth of operators of distribution pipeline systems, the nature of the systems they operate, the requirements they must meet, and the practices that they use to assure safety all vary widely. An understanding of these differences, and the current approach to sharing and using practices that go beyond the regulations, i.e., the “baseline” level of program management, will be useful in understanding the approach being taken to enhance distribution integrity management. Diversity of Operators Operators of distribution pipeline systems subject to OPS/State safety regulation are of four different types: • Master meter systems (e.g., trailer parks, individual multi-occupancy buildings) • Publicly owned (e.g., town/city/county) municipal utilities • Investor-owned utilities • Propane gas distribution systems The order within this list represents the prevalence of each type of operator. There are approximately 1,000 publicly owned utilities delivering gas to consumers in the United States. By contrast, there are approximately 250 investor-owned utilities engaged in this business. <<>> A Report to the Congress: Assuring the Integrity of Gas 6 Distribution Pipeline Systems There are several thousand master meter operators and a few hundred liquid propane (LP) gas systems that are subject to the safety regulations in 49 CFR Part 192. Figure 1 - Distribution systems subject to 49 CFR 192 (Prepared by APGA from E IA data) # of systems 500 450 400 350 300 250 200 150 100 50 0 438 354 Municipal Investor-owned 96 59 69 50 35 20 6 0 10 < 100 100-1000 1000-10000 10000-100000 100000-1 million > 1 million # of customers (from EIA Form 176) Note: EIA does not maintain data on the number of customers served by master meter systems or liquid propane (LP) gas systems. There are several thousand master meter operators, the vast majority of which serve less than 100 customers. There are approximately 200 LP gas systems most of which also serve less than 100 customers. Within each of these groups, the size of individual operators also varies widely, as shown in Figure 1. Publicly-owned utilities tend to be smaller, with a majority serving less than 1,000 customers. In general, investor-owned utilities tend to be larger, with slightly over 100 companies serving more than 100,000 customers each. There are examples, though, of publicly owned utilities serving 100,000 customers and of investor-owned companies serving less than 1,000. The variability makes it difficult to generalize regarding these groups. The particular circumstances of each operator must be taken into account. Master meter operators are businesses such as apartment complexes, or mobile home or trailer parks, or are government entities like housing authorities and universities that receive gas from an outside supplier and distribute it via pipelines located within their facilities. These operators are generally small, with a large majority serving fewer than 100 customers. Distribution of gas, or operation of the distribution systems, is not their principal business. Propane system operators subject to pipeline regulation are also small. Propane used in individual installations, such as a rural farm with its own propane tank, is not subject to regulation as a pipeline system. Propane systems become subject to regulation when they distribute gas, by pipeline, to 10 or more customers. The large majority of these systems likely serve fewer than 100 customers. <<>> A Report to the Congress: Assuring the Integrity of Gas 7 Distribution Pipeline Systems Diversity of Infrastructure The pipeline systems operated by these operators are also subject to much variation. Natural gas has been distributed by pipeline in some areas for over a hundred years. Pipeline systems in these areas were originally small, serving a few customers. These systems merged as larger distribution companies were formed. The materials in use in some of these systems reflect older (e.g., cast iron, copper, bare steel) as well as newer (e.g., polyethylene plastic and cathodically protected coated steel) technology. In other areas, distribution of natural gas by pipeline is a relatively new phenomenon. In some rural areas, for example, gas may not have been available until a transmission pipeline was routed into the vicinity. Then, municipalities or distribution companies may have created a distribution system to bring natural gas service to customers for whom it was previously unavailable. Systems of this nature tend to be relatively uniform in age and type of materials, but the threats to integrity (such as electrical interference from other buried substructures and localized flooding or vehicular traffic patterns) may still vary from one location to another. Additional diversity will likely be introduced as systems age, new customers are added, and portions of the original systems are replaced. Individual master meter systems and propane systems tend to be relatively uniform due to their small size and limited geographical extent. Existing Regulations and Practices The Federal pipeline safety standards in 49 CFR Part 192 provide a common base of requirements applicable to distribution pipeline systems. These standards address design, construction and operation of pipeline systems as well as requirements affecting inspection, maintenance, repair and testing and also qualification of pipeline operations personnel. States are required to adopt these standards as one of the criteria for certifying their pipeline safety programs or for entering into an agreement with OPS to exercise safety jurisdiction. States can, and do, impose additional requirements where appropriate. The National Association of Pipeline Safety Representatives (NAPSR) is an organization consisting of the senior regulatory program manager from each State that exercises pipeline safety jurisdiction. NAPSR recently conducted a survey of its members to identify the extent of additional State requirements that go beyond Part 192. The survey identified that most States impose some additional requirements. A majority impose stricter criteria for reporting incidents and/or requires that operators notify the regulator of construction or testing that would provide an opportunity for the regulator to examine the pipeline and observe safety- significant work. These type of requirements reflect the close oversight relationship that exists between most state regulatory programs and the operators they regulate. State regulators generally interact routinely with operators under their jurisdiction, and therefore know their systems and personnel. States are actively engaged, on a daily basis, in overseeing safe operations. Additionally, approximately 25 percent of the States impose requirements for leak surveys beyond those required in Part 192. <<>> A Report to the Congress: Assuring the Integrity of Gas 8 Distribution Pipeline Systems The NAPSR survey also identified that approximately 65 percent of States have a program to replace some types of distribution piping. This may include cast iron pipe, uncoated and unprotected steel pipe, or certain types of plastic pipe that have been found to be subject to deterioration in service. The replacement programs vary in scope. In some cases, they involve all (or nearly all) of the operators in a State. In other cases, they may involve individual operators and may have been initiated as a result of an incident or event that highlighted problems associated with the aging material. A summary of the NAPSR survey results is included as Attachment 1 to this report. In addition to the NAPSR survey, OPS contacted several larger investor-owned utilities to obtain information about their safety practices that exceed minimum regulatory requirements. The operators surveyed, all of which serve mid- to large-sized cities, all reported that they use risk evaluation to help direct work on their pipelines. This supports a conclusion of the American Gas Foundation (AGF) that 82% of companies they surveyed use risk control practices.7 Use of risk models is not currently required of distri - **truncated:** true - **body characters:** 131702