OGA Technical Seminar Distribution Integrity Management and the Integrity Management Audit Process

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OGA Technical SeminarDistribution Integrity
Management and the Integrity Management Audit
Process

• April 1, 2005

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Progress towards Distribution Integrity
Management Regulations
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Inspector Generals Report

• July 20, 2004 report to US House of Rep.
• Gas Distribution Lines make up 85 of the 2.1
  million miles of natural gas pipelines in the
  United States.
• Natural gas distribution pipelines over the last
  10 years have experienced over 4 times the number
  of fatalities and 3.5 times the number of
  injuries when compared to hazardous liquid and
  transmission pipelines.

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Inspector Generals Report

• Distribution
• 174 fatalities
• 662 injuries

• Transmission and Hazardous Liquids
• 43 fatalities
• 178 injuries

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Transmission/Hazardous Liquid

• 20,000 integrity threats have been identified and
  remediated in less than 16 of the lines
  requiring inspections.
• Mileage still needing baseline integrity
  inspections
• 135,000 Miles Hazardous Liquid
• 326,000 Miles of Transmission

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Inspector Generals Strategy

• Three Elements of DOTs IG Plan
• Understanding the infrastructure
• Identifying and characterizing the threats
• Determining how best to manage the known risks
  (prevention and mitigation issues)

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Inspector Generals Report

• Noted AGF study to be presented in December 2004
• By March 31, 2005, OPS will finalize its approach
  for requiring operators of gas distribution
  pipelines to implement some form of integrity
  management elements

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American Gas Foundation Report

• Looked at three major areas
• Natural Gas Distribution Industry Safety
  Performance
• Current Regulations and Industry Practices that
  address threats to the natural gas distribution
  infrastructure
• Differences between Gas Transmission and Gas
  Distribution Infrastructure

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American Gas Foundation Report- Findings

• Key differences noted between distribution and
  transmission infrastructure
• Type of infrastructure
• System operating pressures
• Materials of construction
• Typical failure mechanisms
• Inspection methods
• Class locations
• Connection to customers

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American Gas Foundation Report- Findings

• Visual inspection of piping is more prevalent in
  distribution than transmission systems.
• Many operators actively participate in damage
  prevention organizations.
• Some one call programs allow exemptions from one
  call membership and not all include
  fines/penalties for offenders.

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American Gas Foundation Report- Findings

• Current pipeline regulations address threats to
  distribution infrastructure.
• Operators employ prevention and mitigation
  practices in excess of those required by law.
• Downward trend in incident fatalities and
  injuries (1990-2002)
• Major cause of incidents is outside force damage
  third party damage

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Allegro Report

• Completed in 2004 for OPS
• Evaluated five years of incident data (1999-2003)
• Attempted to reclassify them into the new cause
  categories listed in the current incident
  reporting forms
• 67 incidents were outside force damage
• 38 excavation and mechanical damage
• 11 vehicle damage-(contributed to 25 of fatal
  incidents)

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DOT Action Plan General Approach

• Building on AGF Report, DIGIT Committee, State
  and Industry Initiatives
• Involve all stakeholders
• Assure flexibility to the maximum extent
  practicable
• Identify strategies to implement selected
  integrity management options (Details Forthcoming)

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Action Plan Team Structure

• Executive Steering Team
• Coordinating Team
• Task Teams

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Team Structure

• Executive Steering Team
• State Commissioners (4),
• Industry/Trade Association (4),
• Public (1),
• Fire Marshall (1),
• OPS (Stacey Gerard)

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Team Structure

• Coordinating Team
• NAPSR (2)
• NARUC (1)
• AGA/APGA (2)
• Public (1)
• OPS (Tom Fortner, Mike Israni)
• Observers (4-Industry, 4-State)

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Team Structure

• Task Teams
• (federal/ state/ industry subject matter experts)
• Strategic Options
• Risk Control
• Data
• Outside Force

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Strategic Options

• Identify options to implement for distribution
  system safety

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Risk Control

• Evaluate the effectiveness and applicability of
  the current regulations as well a reviewing
  current risk control practices in government and
  industry

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Data

• Assemble existing information to identify the
  type, significance, and trends for threats
  affecting distribution pipelines

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Outside Force

• Review Common Ground Alliance database and
  related information to identify practices being
  used to prevent outside force damage and the
  extent of the applications

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Implementation Options to be considered

• Structured Nation-Wide Education Program
• National/local advertising campaign similar
  to call-before you-dig
• Model State Legislation
• Prepare draft language that could be
  incorporated by States into legislation
  addressing distribution pipeline safety issues.

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Implementation Options to be considered

• National Consensus Standard or Guidelines
• National Consensus Standard or other guidance
  document detailing specific practices for
  improving distribution pipeline safety under
  different circumstances.
• Guidance Document for Adoption by States
• Similar to above except made mandatory. States
  could adopt in whole or in part based on local
  needs.

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Implementation Options to be considered

• Simple Flexible Federal Regulation
• Regulation requiring that each operator have an
  integrity plan that reflects (a) knowledge of
  infrastructure, (b) consideration of applicable
  threats, (c) activities to reduce risk, and (d)
  process for monitoring performance.
• Prescriptive Federal Regulation
• Regulation similar to the integrity management
  rule for gas transmission pipelines

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Implementation Options to be considered

• Development of Innovative Safety Technology
• Support research and development of techniques
  to assess the integrity of small-diameter,
  networked pipeline systems of varying materials.

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Action Plan -- Schedule

• Initial Meeting of Executive Steering Team (with
  Coordinating Team) March 16-17
• Task Teams Meeting March 29-31
• Public meeting September
• Recommendations to Executive Steering Team
  December
• Interim products/progress available on OPS
  web/Docket

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Excess Flow Valves

• Older OPEN NTSB recommendation to OPS
• Allegro Report identified 101 incidents where
  excess flow valves possibly might have mitigated
  consequences
• Statewide survey sent out this week- responses
  due by April 15, 2005
• Will be looked at by the Risk Control and Data
  groups
• Mandates forthcoming???
• Part of the Distribution IMP rules???
• OPS is anticipating a public meeting possibly as
  early as June 2005

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OPS Web Site

• http//ops.dot.gov

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Transmission Integrity Management Inspections
for Ohio
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Specific Deadlines

• Past Deadlines
• By June 17, 2004 operators were to have started
  their baseline integrity assessments as outlined
  in November 17, 2003 Advisory Bulletin
• By August 31, 2004 begin semi-annual reporting
  of the four performance measures
• By December 17, 2004- All operators must have a
  written integrity management plan
• Future Deadlines
• 50 Baseline Assessments of covered segments to
  be completed by 12/17/2007
• Finish Baseline Assessments on covered segments
  12/17/12
• Reassess Covered Pipeline Every 7 Years

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Ohio Integrity Management

• Operators without HCAs
• Documentation must be maintained to demonstrate
  that the operator evaluated the system for HCAs
• Will need to have a procedure that would identify
  HCAs if conditions change around the pipeline
  facilities- An operator must be able to
  demonstrate that it has periodically evaluated
  its pipeline for HCAs
• For transmission pipelines operating below 30
  percent of SMYS in class 3 or 4 locations but not
  in an HCA, enhanced protection against
  third-party damage must be implemented in
  accordance with 192.935(d).
• Operators will not have to have an integrity
  management plan until they identify HCAs in
  their pipeline system

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Incorporates by Reference

• If there is a conflict between the regulations
  and the standards then the regulations prevail
• Must/Shall Statements mandatory
• Should Statements are recommended

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Operators Plans/Framework

• Aspects an operator should have completed
• Identify HCAs
• Identify Threats
• Baseline assessment plan
• Remediation??

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Operators Plans/Framework

• Framework allowance
• Rule has allowances for framework aspects of the
  parts of an operators integrity management plan-
  i.e. prevention and mitigation,
• Outlines will NOT be acceptable- must have
  minimal process detail
• Certain aspects such as HCA Identification,
  Baseline Assessments, Remediation, etc. should be
  more detailed

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Gas Integrity Management Plan

• Describe how relevant decisions will be made, by
  whom, and timeline
• Remember that you will need to document
  procedures and processes- this is a new concept
  to operators

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Inspection Forms

• Will utilize the federally developed protocol
  inspection form
• Questions currently available on the OPS
  integrity management website

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Protocol Questions

• 14 sets of questions (A-N)
• Most emphasis on these areas
• A- Identify HCAs
• B- Baseline Assessment Plan
• C- Identify Threats, Data Integration, and Risk
  Assessment
• D- DA Plan (If Applicable)
• E- Remediation
• I- Performance Measures
• J- Recordkeeping

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Ohio Inspections

• Regional Training- End of May for Central Region-
  Seamus Mulligan and Jill Henry
• Ohio will begin inspection in late June early
  July
• Initial round of inspections to be completed in
  2005

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Initial Screening Questions

• List of screening questions has been
  developed-(Hopefully send the first week of
  April)
• Will be sent out to the transmission operators
  for completion by the end of April 2005.
• These questions will help us prioritize the
  inspection schedule and determine if a pre-audit
  meeting is necessary.
• Will help us determine which protocol questions
  will be applicable.

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Ohio IMP Audits

• Pre-audit meeting will only be scheduled as
  necessary
• Will probably ask for a copy of the plan prior to
  the audit for review
• Anticipate most audits being under a week (larger
  operators will be scheduled for two weeks)-
  screening questions will help estimate audit time

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Special Issues/Concerns

• Dont wait until the audit to bring up questions-
  please ask now!
• We are trying to address everyones concerns
  equally and apply the rules consistently
• Anticipate issues for LDCs operating small
  amounts of Transmission
• Regulations are complicated-dont expect to be an
  expert

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OPS Web Site

• http//ops.dot.gov

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Further Information

• Jill Henry
• at
• 614-728-2137
• or
• jill.henry_at_puc.state.oh.us