Paul J. MetroManager Gas Safety Bureau

ENERGY ASSOCIATION OF PENNSYLVANIA

JUNE 1, 2012

AGENDA2011 StatisticsNational Pipeline Safety IssuesPennsylvania Pipeline Safety IssuesGas Safety Division Reorganization

GAS SAFETY STATISTICS2011 REPORTABLE INCIDENTS

5 Reportable Incidents2 Corrosion Related – Cast Iron

Failures2 Underground Facility Line Hits1 Operator Error

REPORTABLE INCIDENTSPhiladelphia , Allentown, San Bruno

Changed the Nation’s Gas Safety Perspective More Regulations

Documented MAOP CalculationsPipeline Replacement ProgramsMore Prescriptive DIMP/IMP RegulationsLess Risk Based- More Prescriptive – A

Better BalanceMore “Boots on the Ground”

REPORTABLE INCIDENTS

Facility Damages – Natural GasPennsylvania’s Average is 2 Reportable Incidents per Year related to Facility DamagesNeed Greater Enforcement

REPORTABLE INCIDENTS -OPERATOR ERROR

Pennsylvania has been Averaging 1 Reportable Incident per Year related to Operator ErrorNeed to Review Operator Qualification Programs with a Sensitivity AnalysisObserving Issues with More Experienced WorkersGas Safety will Focus Inspections on OQ

PIPELINE SAFETY STATISTICSGas Safety Issued 71 Non-Compliance Letters during 2011

Issued 72 Non-Compliance Letters during 2010One Pa Operator had 23 of the 71 Non-Compliance LettersGas Safety Will Focus on Three Areas:

Damage PreventionCorrosionOQ

GAS SAFETY STATISTICS - 2011

• Gas Safety Issued $101,500 in Assessed Civil Penalties • 49 CFR 192.614 – Damage

Prevention Program - Most Number of Violations• 49 CFR 192.13(c) – Procedures –

Second Most Number of Violations

DAMAGE PREVENTION STATISTICS 2011

• Slight Decrease to the Number of Facility Damages (Construction was down in 2011)

• Total Cost of Facility Damages Slightly Higher• Gas Safety will Continue to Address Utility Fault

Issues through Civil Penalties• Mapping Errors, No Locates, Lines Marked

Incorrectly Account for Approximately 36% of Facility Damages (2010 – 39%)

0

100

200

300

400

500

600

700

Reason for Facility Damage

0

50

100

150

200

250

300

350

400

450

Private R/W PublicProperty

Public R/W Sidewalk Street Yard

Total 2011 Damage Locations

0

500

1000

1500

2000

2500

3000

3500

2004 2005 2006 2007 2008 2009 2010 2011

Total Number of Yearly Damages

$-

$500,000

$1,000,000

$1,500,000

$2,000,000

$2,500,000

$3,000,000

$3,500,000

$4,000,000

2004 2005 2006 2007 2008 2009 2010 2011

Total Cost of Yearly Damages

0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0

2004 2005 2006 2007 2008 2009 2010 2011

Yearly Average of Line Hits Per 1000 Tickets Marked

NATIONAL PIPELINE SAFETY ISSUES• Modifying the definition of an HCA• Strengthening the Integrity Management

requirements in Part 192• Modifying repair criteria• Revising the requirements for collecting,

validating, and integrating pipeline data• Making requirements related to the nature

and application of risk models more prescriptive

NATIONAL PIPELINE SAFETY ISSUES• Strengthening requirements for applying knowledge

gained through the IM program• Strengthening requirements on the selection and use

of assessment methods, including prescribing assessment methods for certain threats (such as manufacturing and construction defects, SCC, etc.) or in certain situations such as when certain knowledge is not available or data is missing

• Valve spacing and the need for remotely- or automatically-controlled valves

• Corrosion control

NATIONAL PIPELINE SAFETY ISSUES• Pipe with longitudinal weld seams with systemic

integrity issues• Establishing requirements applicable to underground

gas storage• Management of Change• Quality Management Systems (QMS)• Exemptions applicable to facilities installed prior to

the regulations• Gathering lines

NATIONAL PIPELINE SAFETY ISSUES

• Transparency• Inspection Data Reporting• National Data Base

PENNSYLVANIA PIPELINE SAFETY ISSUES –“FROM THE FIELD”

IMP Plans – Utilities Don’t Understand the Content of Their Program, Missing Pipelines, Not Following Their IMP PlansDocumentation of atmospheric corrosion has not been clear. This needs to be maintained for all exposed piping--regulator stations, bridge and stream crossings, meter sets, etc.Corrosion - Remaining wall thickness needs to be documented when "severe" atmospheric corrosion is present.

PENNSYLVANIA PIPELINE SAFETY ISSUES –“FROM THE FIELD”

• Observing an increase in mismarks from the utilities that use subcontractors for the markings. Their appears to be a quality control issue

• Plastic Pipe Failure Reporting – Need more detailed information, utilities are not documenting failure information properly

• DIMP – Incomplete Risk Assessments, Not including all distribution pipe, don’t know what is in the ground

• Pipeline Replacement Programs should be a mitigation measure in the DIMP Program

GAS SAFETY REORGANIZATION

• In the Fall of 2011, The Commission reorganized the Office of Trial Staff and the Bureau of Transportation and Safety into the Bureau of Investigation and Enforcement

Increased Enforcement ActionsFormal ComplaintsCivil Penalties

GAS SAFETY REORGANIZATION

Created 2 Divisions in Gas SafetyDistributionAct 127

Created 2 Supervisor Positions for DistributionRalph Graeser and Bob Biggard

GAS SAFETY REORGANIZATION

Act 127Will hire 5 additional engineers2 Supervisors – Chris Demarco and Mike Chilek

Pooling Engineers

WHAT IS THIS?

ACTIVE OIL WELL AT MCDONALD’S DRIVE THRU –BRADFORD, PA

GAS SAFETY PARTNERS

• The Pennsylvania Gas Pipeline Operators and Public Utilities are partnered in pipeline safety• Increase Communications• Gas Safety offers to meet quarterly or

monthly to discuss safety issues• Call Anytime

• Paul Metro• Manager Gas Safety• PAPUC• 717.787.1063• pmetro@pa.gov