Ohio Gas Association Small Company Symposium

1
Ohio Gas AssociationSmall Company Symposium

• Edward M. Steele
• October 25, 2007

2
Current Issues in GPS

• Plastic Pipe Storage
• Waivers
• Leak Grading and Follow up
• Minimum Service Standards
• Risers

3
Plastic Pipe Storage

• 192.59 Plastic Pipe
• (a) New plastic pipe is qualified for use under
  this Part (Part 192) if
• (1) It is manufactured in accordance with a
  listed specification
• Appendix B
• 1. Listed Pipe Specifications

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Plastic Pipe Storage

• 192.7 Incorporated by reference
• (a) Any documents or portions thereof
  incorporated by reference in this part are
  included in this part as though set out in full.
  When only a portion of a document is referenced,
  the remainder is not incorporated in this part.
• (c) The full titles of documents incorporated
  by reference, in whole or in part, are provided
  herein.
• (2) Documents incorporated by reference
• (10) ASTM Designation D2513-87 "Standard
  Specification for Thermoplastic Gas Pressure
  Pipe, Tubing, and Fittings.
• (11) ASTM Designation D2513-99 "Standard
  Specification for Thermoplastic Gas Pressure
  Pipe, Tubing, and Fittings.

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Plastic Pipe Storage

• A1.5.7 Outdoor Storage Stability
• PE pipe stored outdoors and unprotected for at
  least two years from date of manufacture shall
  meet all the requirements of this specification.
• PE pipe stored outdoors for over two years from
  date of manufacture is suitable for use if it
  meets the requirements of this specification

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Plastic Pipe Storage

• For outside storage, you must consider
• UV Exposure
• Time pipe was stored at manufacturer
• Time pipe was stored at your location
• If exceeds two years You must retest or destroy!

7
Waivers

• Anytime an operator is requesting a waiver
• Following must be true
• You must contact the state agency first
• You should contact state agency as soon as you
  are aware of possible need for a waiver
• You must not be in noncompliance at the time

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Waivers

• Following must be true
• You must provide adequate data on why safety will
  not be compromised
• You must give detailed report on what facilities
  and records you are asking for
• Understand that even if the state approves the
  waiver, PHMSA has up to 60 days to review it
  before it becomes official.

9
Leak Grading and Follow up

• January 6, 2005
• Commission updated GPS rules and added
  Inspections and Leak Classifications
• 49011-16-04(H) and (I)

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Leak Grading and Follow up

• (H) Classify all hazardous leaks immediately and
  classify all other leaks within two business days
  of discovery, utilizing the following standards
  for leak classification, monitoring, and repair

11
Leak Grading and Follow up

• 1) A grade one leak represents an existing or
  probable hazard to persons or property, and
  requires immediate repair or continuous action
  until the conditions are no longer hazardous.

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Leak Grading and Follow up

• (2) A grade two leak is that recognized as being
  nonhazardous at the time of detection, but
  requires scheduled repair based upon the severity
  and/or location of the leak.

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Leak Grading and Follow up

• (3) A grade three leak is that recognized as
  non-hazardous at the time of detection and can be
  reasonably expected to remain non-hazardous.

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Leak Grading and Follow up

• (I) Upon discovery of any leak, take the
  following actions
• (1) Take immediate action on grade one leaks to
  protect life and property and continuous action
  until the condition is no longer hazardous. This
  may require but is not limited to implementation
  of the operator's emergency plan.

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Leak Grading and Follow up

• 2) Repair or clear grade two leaks no later than
  fifteen months from the date the leak is
  discovered, unless the pipeline containing the
  leak is replaced within twenty-four months from
  the date the leak is discovered. Grade two leaks
  shall be reevaluated at least once every six
  months until cleared.

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Leak Grading and Follow up

• (3) Reevaluate grade three leaks during the next
  scheduled survey or within fifteen months from
  the date of the last inspection (whichever is
  sooner) and continue to reevaluate such leaks on
  that same frequency until the leak is repaired or
  there is no longer any indication of leakage.

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Leak Grading and Follow up

• Venting of leaks
• Thinking of proposing new law where you can only
  vent a leak for 6 months until it must be
  permanently repaired
• Would not include venting of leaks in sewer
• Not acceptable under current regulations

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Minimum Service Standards

• Our interpretation
• New Installations
• Pressure test service line and house lines.
• Cannot use a valve just downstream of the meter
• If pressure test failure isolated to
  appliance-shut appliance valves to isolate and
  red tag house line to the leaking appliance-
  establish service to remaining portion of
  houseline.
• OR
• If pressure test fails and cannot be isolated to
  an appliance- service not established- meter stop
  locked and door tag left.

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Minimum Service Standards

• Replacements
• Pressure test service line and house lines.
• If pressure test failure isolated to
  appliance-shut appliance valves to isolate and
  red tag house line to the leaking appliance-
  establish service to remaining portion of
  houseline.
• OR
• If pressure test fails and cannot be isolated to
  an appliance- service not established- meter stop
  locked and door tag left.
• If pressure test successful-then service
  established.

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Minimum Service Standards

• Turn on (less than 30 days)
• Pressure test or meter dial test service line and
  house lines.
• If pressure test or meter dial test failure
  isolated to an appliance-shut appliance valves to
  isolate and red tag house line to the leaking
  appliance- establish service to remaining portion
  of houseline.
• OR
• If pressure test or meter dial test fails and
  cannot be isolated to an appliance- service not
  established- meter stop locked and door tag left.
• If pressure test or meter dial test
  successful-then service established.

21
Minimum Service Standards

• Turn on (greater than 30 days)
• Pressure test service line and house lines.
• If pressure test failure isolated to
  appliance-shut appliance valves to isolate and
  red tag house line to the leaking appliance-
  establish service to remaining portion of
  houseline.
• OR
• If pressure test fails and cannot be isolated to
  an appliance- service not established- meter stop
  locked and door tag left.
• If pressure test successful-then service
  established.

22
Risers

• Staff filed report on November 24, 2006
• Chairman letter January 2, 2007
• 2nd Chairman letter January 23, 2007
• Comments filed first two weeks of February

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Risers

• Chairman sent out two letters
• January 2, 2007
• January 23, 2007
• Filed in the docket

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Risers

• If company finds riser in condition of the failed
  risers detailed in the staff report
• Deal with it immediately
• Proactively repair or replace any riser
  identified as meeting the conditions in the staff
  report

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Risers

• Take measures in reaction to the staff
  recommendations
• At a minimum
• Begin riser inventory to identify types and
  locations of risers in your system
• Discussion of Utilities taking over
  responsibility for customer owned service lines

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Risers

• On 4/25/07, COH filed application for approval of
  tariffs
• To recover costs associated with
• Riser inventory
• Replacement of customer owned service lines that
  COH believes are prone to failure
• Replacement of customer owned service lines that
  are constructed or installed by COH as risers are
  replaced

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Risers

• July 11
• Commission approved in part (and deferred in
  part) and ordered COH to file modified tariffs
  for Commission approval

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Risers

• Granted approval for COH to replace all risers
  prone to failure
• Replace service lines if leaking only on
  associated service lines
• Rest of items in COHs application of 4/25/07

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Risers

• Hearing will be held on Monday October 29, 2007
  in Hearing Room 11-C on the 11th floor of the
  Commissions office