Gas Pipeline Safety

Ohio’s One-Stop Utility Resource

Gas Pipeline Safety

Ed Steele, Section ChiefGas Pipeline Safety Section


Program Structure• The Gas Pipeline Safety Program is a Federally certified program

(Intrastate and Interstate agent)• In order to participate, each state must file a certification with the

Federal Government each year• In that certification, you must list your past year’s performance,

estimated costs, incidents, inspector qualification, and jurisdictional operators.

• In return, each state receives up to 50% of their funding from the Federal Government based on performance, jurisdiction, and qualifications.

• The remaining portion of our funding comes from the utility assessment and an additional assessment specifically on GPS operators.


Rules

• Ohio Revised Code– 4905.90 through 4505.96

•Regulatory authority

• Ohio Administrative Code– 4901:1‐16

•Rules developed to enforce regulatory authority– We adopt the Federal Minimum Gas Pipeline Safety Standards as part of these rules


Rules

• Adopt Federal Regulations• Additional requirements

– Construction reporting– Leak Classification– Master Meter Annual Reporting– Annual Incident/Outage/Construction reports


Regulations

• 49 CFR (Code of Federal Regulation)– Part 192 – Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards

– Part 191 – Transportation of Natural and Other Gas by Pipeline: Annual Reports, Incident Reports, and Safety Related Condition Reports

– Part 199 – Drug and Alcohol Testing– Part 40 – Drug and Alcohol Testing Procedures


Regulations• 49 CFR Part 192

– Regulations covering the following:•Materials•Design•Welding of steel• Joining of materials other than by welding•General Construction•Corrosion Control•Test requirements•Uprating


Regulations (continued)•Operations•Maintenance•Qualification of Personnel•Integrity Management


Material

• Types of Pipe– Steel– Plastic

• Marking of materials


• Design formula– Steel pipe– Plastic pipe

• Yield Strength• Limitations for plastic pipe

Pipe Design


Welding of Steel

• Procedures• Qualification of welders• Protection from weather• Nondestructive testing• Repair or removal of defects


Joining of Materials Other Than by Welding

• Plastic Pipe– Fusion– Qualified joining procedure– Qualification of employees to this procedure

• Metallic Pipe– Couplings


General Construction

• Installation– Inspection of materials– Depth of installation– Proper backfill– Casings– Underground clearance


Corrosion Control

• External Corrosion– Pipelines installed after July 31, 1971– Pipelines installed before August 1, 1971


Corrosion Control

• Protective Coating• Cathodic Protection• Monitoring

– Test Stations• Interference• Atmospheric Corrosion• Remedial Measures


Test Requirements

• >30% SMYS (life of pipeline)• <30% SMYS but above 100 psi (life of pipeline)

• <100 psi (5 years)• Plastic Pipe (5 years)

– Must keep records for the life of the pipeline on these tests


Uprating

• Required when you need additional supply in the pipeline– Review of pipeline system history– Written plan– Done in increments (25%), pressure held constant, system checked for leaks

– Records kept for life of pipeline


Operations

• Operation and Maintenance procedures• Review of population along the pipeline• Continuing Surveillance• Damage Prevention Program• Emergency Plan• Public Education


Operations

• Establishment of Maximum Allowable Operating Pressure

• Odorization of Gas• Purging of Pipelines


Maintenance

• Leakage Surveys• Line Markers• Repair Records• Patrolling• Abandonment of Facilities


Maintenance

• Pressure limiting stations• Overpressure Protection • Valve maintenance


Operator Qualification

• Qualifications of individuals performing covered tasks on a pipeline– Covered task

•Performed on a pipeline•Operations or maintenance task•Performed as requirement of Pipeline Safety Code•Affects the operation or integrity of the pipeline


Operator Qualification

• Identify covered tasks and intervals• Evaluate individuals performing covered tasks to ensure that they are qualified

• Keep records


Pipeline Integrity Management

• For Transmission Pipelines– our newest addition to the regulations‐ requires more documentation and process evaluation than other parts of 192

• Developed as a result of some major pipeline incidents


Pipeline Integrity ManagementRequires operators to:• Identify high consequence areas in their pipeline system• Identify potential threats (third party damage, corrosion,

construction, manufacturing, weather, etc.)• Determine the risk and consequences of failure in these

areas.• Develop a baseline assessment plan (risk ranking of the

HCA’s)• Conduct assessments by: in‐line pigging, pressure testing,

or Direct Assessment


Pipeline Integrity Management• Requires them to remediate/repair specific anomalies found during assessment‐dents/cracks/wall loss areas

• Develop preventative and mitigative measures‐extra monitoring during excavations near their pipelines, adding extra valves, performing extra or accelerated leakage surveys, etc.

• Develop a continual evaluation and reassessment plan

• They will assess all HCA’s by 2012‐ 50% by 2007


Staff• Chief, Ed Steele, 19 years in GPS, Chief for 14• Administrative Assistant, Tina Holbert ‐15 years• Field Investigators

Joel Zavitz ‐ 22 yearsBill Rubenstahl ‐ 19 years Victor Omameh ‐ 17 years Ted Ressler ‐ 12 yearsJill Henry ‐ 11 yearsPaul Hollinger ‐ 6 years Mike Purcell – 1 + year Mary Alspach – 1 year

• In the process of hiring another investigator


Training• Transportation Safety Institute

– Week long classes held in Oklahoma City, OK• PL00250 – Safety Evaluation of Gas Pipeline Systems• PL00254 – Joining of Pipeline Materials• PL00255 – Gas Pressure Regulation and Overpressure protection• PL00256 – Pipeline Failure Investigative Techniques• PL00257 – Pipeline Safety Regulation Application and Compliance Procedures• PL00291 – Fundamentals of Supervisory Control and Data Acquisition

(SCADA) Systems Technology & Operation• PL00292 – Safety Evaluation of Inline Inspection (ILI) / Pigging Program• PL00293 – Corrosion Control of Pipeline Systems

– Receiving a 70% grade on the final exam is required to pass and to keep employment with the P.U.C.O.


Training• In addition to these classes, several computer based training CDs and DVDs have been developed and are mandatory:– Operator Qualification– Integrity Management

• 7 developed to date– Internal Corrosion

• We also attend and are required to pass the Appalachian Underground Corrosion Short Courses in Morgantown, WV.– Basic, Intermediate and Advanced courses


Inspections• Inspections

– Intrastate (start and stop within the state)•Distribution•Transmission•Municipal•Master Meter•Gathering Lines

– Interstate (cross state borders)•Transmission•Storage Facilities•Compressor Stations

– New Construction– Incident Investigations– Safety Related Conditions

– Complaints/Inquiries


Inspections• Intrastate

– 163 Intrastate operators (223 inspection Units)• Each inspection includes:

– Operation and Maintenance procedures– Emergency Plan review– Record review– Field verification– Drug and Alcohol procedures and testing– Operator Qualifications– Incident Investigation (where appropriate)

• These audits can take anywhere between a few days to four weeks to complete.


What We Do

• Interstate Transmission– 8 Interstate Operators (17 Inspection Units)– We are agents of the Federal Government for all interstate inspections•We do all of the inspections and refer any corrective action/forfeitures to the Feds for their enforcement action

– Look at the same compliance requirements as intrastate operators


Inspections

• Our inspection / audits consist of the following:– Review of company procedures and policies– Review of company records– Observation of work done by company employees in the field

– Comparison of company records to condition of items in the field


Inspections

• All reviewed records / procedures / field items are documented on the inspection form– Condition of field facilities– Records that are reviewed


Enforcement• Non‐compliances

– Whenever an operator does not comply with the GPS rules and regulations• We issue a notice of probable noncompliance

– Investigator follows up on this until it is corrected• If it is a repeat or egregious violation, GPS has the option to open a GPS case which is decided on by the Commission– In most cases, whenever a GPS is opened, there is normally a civil penalty involved

• GPS can now collect $100,000 per day per violation up to a cap of $500,000 for a related series of violations

• Since we started collection civil penalties in 1988, GPS has collected over $850,000 in collected fines.


New Construction

• All new or replacement pipeline construction that exceeds $200,000 must be reported to GPS– GPS will investigate these projects to ensure compliance with applicable GPS regulations•Proper Material• Installation•Qualifications


Incident Investigations

•Whenever there is a unintended release of gas that results in:– Death– Personal Injury requiring in‐patient hospitalization

– Property damage (including the cost of gas lost) that exceeds $50,000

• Operator must call GPS within 2 hours


Incident Investigations

• GPS will send an investigator to the scene to determine:– Procedures were followed– Operator was in or out of compliance– Emergency plan was followed


Outage Reports

• Each operator must report to the GPS Section each outage of 100 or more customers that exists for more than 2 hours– 30 and 60 day follow up reports.


Safety Related Conditions

• Whenever an operator discovers a condition on the pipeline that compromises its integrity, as described in 191.23, they must report it to GPS– Describing the situation– Describing what they did to make the situation safe

– How the will correct the problem• GPS will follow up on this report


Complaints/Inquiries• These come from several sources

– IAD (formerly PIC)– Public– Consumers– Disgruntled ex‐employees– Legislature

• GPS will investigate, make sure the situation is safe and try to resolve the issue


New Federal Requirements

• Operator Qualification• Integrity Management


Future Items

• Statewide Riser Investigation • New Gathering line definition• Kicking off Transmission Integrity Management

• Distribution Integrity Management

Documents

Gas Pipeline Safety