Natural Gas Safety Report to - CRU Ireland

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2009 Natural Gas Safety Framework – Report to the Minister

Annual Gas Safety Report

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Foreword

The CER has taken on an important function of gas safety since the enactment of the Energy

(Miscellaneous Provisions) Act at the end of 2006. We have discharged this obligation through

the establishment of a Natural Gas Safety Regulatory Framework (the framework) in which we

aim to reach a position in Ireland that meets best international practice. The framework aims to

protect natural gas customers and the public generally from hazardous events ranging in

frequency and severity, and ensures that adequate measures are taken to protect life and property

from the dangers associated with natural gas. This includes all natural gas storage, transportation,

supply and use activities onshore in the Republic of Ireland.

The CER has engaged with the natural gas industry to ensure that gas undertakings can

demonstrate to the CER’s satisfaction that safety is a prime consideration in the operation of their

businesses. The industry has presented safety cases to the CER which have been rigorously

scrutinised and will be subjected to ongoing assessment and inspection. The 2006 Act specifically

requires the CER to regulate onshore natural gas undertakings and registered gas installers with

respect to safety and to promote the safety of natural gas customers and the public generally. The

Framework identifies key methods for safety management including the promotion of gas safety;

the management and demonstration of operational risk through a safety case; registration and

inspection of gas installers; reporting and investigation of natural gas incidents; and management

of safety performance through reporting, review, inspection and audit requirements.

The key areas of activity during 2008 and 2009 saw the majority of undertakings having

completed an acceptable safety case, and the full establishment of the Register of Gas Installers of

Ireland and the registration of natural gas installers.

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Report Summary

This report summarises the performance of the natural gas undertakings regulated under the

Framework, through analysis of incidents, operational statistics and technical inspections and

audits, and compares performance against prescribed high level objectives. The Commission also

ensures that each undertaking manages risk through a safety case where asset based risk is

evaluated and managed.

The 2009 period has seen strong progress in implementing the requirements of the Energy

(Miscellaneous Provisions) Act 2006. Safety Case regimes are now fully operable for gas

transportation (transmission and distribution) operations, with many shippers and suppliers also

completing the safety case development process.

The following undertakings have submitted acceptable safety cases to the CER to date (June 2010):

Undertaking/Licence Transmission Distribution Gas Storage Shipper/Supplier Gaslink

PSE Kinsale Energy*

Bord Gáis Energy

Gazprom

ESB

Manx Electricity Auth.

Energia

Flogas

Airtricity

Tynagh

Aughinish Alumina

Huntstown

Phoenix Energy


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*Gas Storage (Interim) safety case from Marathon Oil Ireland Ltd was assessed and accepted by the CER in February

2009. Following a change in ownership a revised safety case is pending.

The mandatory requirement for gas installers to be registered also progressed significantly in

2009, with the appointment of the Register of Gas Installers of Ireland (RGII) as the new

regulatory body responsible for registering and inspecting the work of natural gas installers

(Registered Gas Installers). Firm operational protocols were also established for the registration

of gas installers which facilitated the transition of around 2,700 installers onto the RGII. A gas

safety promotion strategy and programme has also been established with an active itinerary,

including press, radio and television advertising. The CER also carried out a national road show,

presenting to installer groups and addressing individual and collective concerns.

There were four significant natural gas related incidents during 2009, none of which involved any

fatalities or serious injuries. One incident was due to a damaged external gas main, the other

three due to issues with customer’s gas installations. One incident in Blackrock, Dublin caused

significant property damage.

Incident Location Incident Date Incident Type* Learning Outcomes Grand Parade, Dublin 10/01/2009 NR Y Temple Road, Blackrock, Co. Dublin

14/03/2009 B N

Milltown Drive, Dublin

18/12/2009 C Y

Donore Road, Dublin 19/12/2009 C Y * Denotes incident type: A – Involves a fatality; B – Injury requiring hospitalisation; C‐ property damage in excess of €6,350; NR – A

non‐reportable incident that may have other significance or learning.


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Incidence of gas escaping following a pipe or installation fault, or pipe damage, is falling year on

year. The year has also seen performance or technological improvement in pipeline protection,

corrosion management, and pressure control.

Management of gas quality parameters (ensuring components in gas remain within safe limits)

and odorant (added to give gas a distinctive smell) has been highly efficient. Response to

customers reporting gas escapes maintained high performance levels, with only 17 responses out

of 20,332 taking longer than 1 hour; this was due to flooding and snow.

It is notable that there were two fatalities following a Carbon Monoxide incident at Glenties, Co.

Donegal during September. These related to an LPG cooker installation. The CER provided

substantial support to the ensuing investigation. The CER’s Safety Division have worked closely

with the DCENR in developing new proposals for LPG which were recently released for industry

consultation. These proposals form the basis for planned legislative changes to bring LPG safety

regulation under the CER’s auspices.


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Introduction

The purpose of this report is to provide a summary of the safety performance of the natural gas

industry during 2009, with particular focus on the Natural Gas Safety Framework and the

processes that are encompassed by it. The report will identify the principal objectives of this

framework, describe developments during 2009 and provide analysis and review of safety

performance and compliance.

Following the enactment of the 2006 Energy (Miscellaneous Provisions) Act (the 2006 Act) the

Commission for Energy Regulation (CER) was required to introduce new measures to regulate the

safety performance of the Irish Natural Gas industry. The scope of this legislation encompassed all

industry boundaries and included undertakings in gas storage; transportation; commercial gas

supply and shipping; and safe gas utilisation. Such a remit required safety regulation of both semi

state and private businesses through active and responsive risk management strategies.

During 2007 a safety vision and strategy was developed for the foreseeable industry picture and

wide ranging industry consultations were instigated. The result was to develop and implement a

Natural Gas Safety Regulatory Framework (the Framework).

The current Framework is illustrated in Figure 1 below and is constantly evolving. The generic

strategy is twofold; firstly to ensure that industry safety requirements were fulfilled competently

and; to promote and develop public perception, and therefore knowledge, of gas safety. The

strategic objective of the framework is:

To ensure that adequate measures are taken to protect life and property from the

dangers associated with natural gas by ensuring that gas related activities within

the scope of the Commission’s responsibilities are carried out in a safe manner,


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which takes account of and mitigates against the risks associated with the storage,

transportation, supply and use of gas.

To develop a practical solution it was then necessary to identify the high level safety targets and

functional safety controls. These principal objectives are as follows:

Key Objective 1: Minimising the Risk of Loss of Containment

Gas undertakings will be required to demonstrate that they have suitable management

systems and procedures in place for managing the risks that lead to, and arise from, loss of

gas containment events.

Key Objective 2: Maintaining Safe System Operating Pressure

Gas undertakings will be required to demonstrate that they have suitable management

systems in place for managing the risks that can result in dangerously high or low gas

operating pressure in the pipeline system(s).

Key Objective 3: Minimising the Risk of Injecting Gas of Non‐Conforming Quality

Gas emergency incidents can arise due to gas of inappropriate quality being injected into

the system and, as such, gas undertakings will be required to demonstrate that they have

suitable management systems in place for gas quality monitoring and for managing the

risks associated with the quality of gas that is injected into the system.

Key Objective 4: Providing an Efficient and Coordinated Response to Gas

Emergencies


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Gas emergency events can and do occur for a variety of reasons including the actions of

third parties. Bord Gáis Networks will be required to demonstrate that it has suitable

arrangements in place for: (i) managing the response to ‘localised’ gas emergencies; and

(ii) undertaking the role of Network Emergency Manager during ‘network’ gas

emergencies. Additionally, all gas undertakings will be required to demonstrate that they

have suitable arrangements in place for responding to the requirements of the Network

Emergency Manager in the event of large‐scale ‘network’ gas emergencies being declared

by the Network Emergency Manager.

As stated in section 5.4 below, the operators of major accident hazard facilities such as

LNG terminals and gas storage facilities have responsibility for the on‐site management of

gas emergencies within the confines of their installations. The role of the NEM in such

circumstances is to manage the downstream impacts of such emergencies within the

transmission and distribution networks.

Key Objective 5: Minimising the Safety Risks Associated with the Utilisation of Gas

The Framework provides for a comprehensive regime relating to the regulation of gas

installers. The key aim of this regime is that all categories of ‘gas works’ designated by the

CER are only undertaken by competent gas installers who are registered, and subject to

ongoing regulation and inspection, by the Gas Safety Supervisory Body appointed by the

CER. The connection and re‐connection of customers’ installations to the gas supply

network and the servicing of such installations is an important safety risk issue that will be

addressed within the scope of this objective. Customer education and safety awareness is

also an important part of this gas safety objective as discussed in key objective 6.


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Key Objective 6: Promoting Public Awareness of Gas Safety

Increasing the level of gas safety awareness amongst gas customers and the public

generally and, in particular, educating on the dangers of carbon monoxide is an important

aspect of the CER’s overall objective of promoting the safety of customers and the general

public in respect of the use of gas. It is also important that owners/occupiers of premises

are aware of their responsibilities in respect to the maintenance of gas fittings

downstream of the meter. To this end, the Framework places duties and obligations on

both individual gas undertakings and the industry generally for the promotion of gas

safety awareness. This involves a combination of both individual and co‐ordinated safety

promotional activities by undertakings.

These key objectives provided the foundation to develop the components of the gas

regulatory safety framework, which would provide data and information to enable key

performance measures to be implemented. The component parts of the framework are

described below as:

a) A Gas Safety Case regime, which uses a risk and outcomes based approach to the

management of gas safety risks to a level that is as low as reasonably practicable, for each

licensed undertaking;

b) A Gas Safety Supervisory Body responsible for the registration of gas installers that meet

specified criteria of training and competency, and subsequently regulates gas installers via

an ongoing inspection and audit regime of work against specified standards;


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c) A Gas Safety Promotion and Public Awareness regime that is designed to increase the

overall level of gas safety awareness amongst customers and the general public on gas

safety matters based on coordinated and individual undertaking’s safety promotional

activity;

d) An Incident Reporting and Investigation regime that fulfils obligations for the

reporting and investigation of incidents by Bord Gáis Networks, the reporting on the

outcomes of incident investigations by Bord Gáis Networks to the CER, independent CER

investigations and subsequent reports by the CER to the Minister. This will also include

for incident reporting and investigation requirements by the operators of major accident

hazard facilities – e.g. LNG and gas storage operators.

e) An Audit and Inspections regime that the CER will use to gain assurance that the

various undertakings are operating in compliance with the gas safety management and

emergency response arrangements as described in their respective safety cases, and the

Gas Safety Supervisory Body in accordance with its Terms and Conditions of

Appointment; and

f) A Gas Safety Reporting Framework that utilises a suite of gas safety performance

indicators to monitor trends and provide assurance that the intended outcomes of the

Framework are being achieved.

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Energy (Miscellaneous Provisions) Act 2006

Strategic Approach to Gas Safety RegulationNon-Prescriptive Approach

Appropriate RegulationRelevant to a Liberalised Gas Market

Risk and Outcomes BasedCommission Role of Securing Compliance

Gas Safety Regulatory Objectives (KPI’s)Minimising Risk of Loss of Containment

Maintaining Safe System Operating PressureMinimising the Risk of Injecting Gas of Non-Conforming Quality

Providing and Efficient and Coordinated Response to Gas EmergenciesMinimising the Safety risks Associated with the Utilisation of Gas

Promoting Public Awareness of Gas Safety

Gas Safety Case RegimeSafety Case Guidelines

Facility DescriptionFormal Safety Risk Assessment

Safety Management SystemEmergency Procedures

Safety Reporting Framework

Gas Safety Supervisory Body

Registration of Gas Installers Safety Inspections & AuditsInvestigation of Complaints

Gas Industry Safety Reporting Regime

Incident ReportingParticipant Quarterly Reports to Commission

Commission Annual Report to Minister

Minister for Communications, Energy

and Natural Resources

Gas Incident Investigation and Reporting Regime

Incident Investigationand Reporting to

Minister

Gas Safety Promotion and Public

AwarenessCoordinated Safety Advertising

Promotion of Gas SafetyGas Safety Initiatives

Gas Safety Forum

Analysis of Safety Outcomes and

Continual Improvement Process

Natural Gas Safety Regulatory Framework

Safety Case

Guidelines

Safety Case

Guidelines

Safety Case

Guidelines

Safety Case

Guidelines

SafetyCase

Guidelines

Safety Case

SafetyCase

SafetyCase

SafetyCase

SafetyCase

LNGTerminals

StorageOperators Transmission Distribution

Shipping&

Supply

Major Emergency Plans and NEM Framework

SafetyReporting

SafetyReporting

SafetyReporting

SafetyReporting

SafetyReporting

CER Licensed Gas Entities

Natural Gas Installers and Installations

Natural Gas SafetyReporting

Audits and Inspections

Regime

Strategic Safety Objective“To Ensure the Protection of Life and Property”

Figure 1: The Natural Gas Regulatory Framework

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Annual Framework Development Report for 2009

The Framework has seen considerable development during 2009. This activity ranges from

establishment of the Register of Gas Installers of Ireland (RGII) and handover from the earlier

voluntary scheme; development of criteria for inspections and audit processes; early work on

expanding the scope of the framework to include LPG and implementation of Framework

strategies for safety cases, safety promotion, incident investigation and safety reporting. The

following summary seeks to capture these works by Framework function:

Gas Safety Case Regime

The principle for requiring a safety case places an onus upon gas undertakings to actively identify,

review and demonstrate risk based management processes that quantify the risks of operating

their businesses. It also drives the undertaking to develop continuous improvement philosophies

which iterate and grow an improving safety profile.

The start of 2009 saw the distribution and transmission undertakings begin fully reporting

operational performance using a series of Key Performance Indicators (KPI’s) and the first

functional audits of the same undertakings. The safety case assessment process seeks to establish

if each undertaking has adequate arrangements in place to competently manage the foreseeable

operational risks posed by their assets. This enabled the CER to develop a fuller picture of asset

risk and performance to ensure, as far as is reasonably practicable, the safe operation of the gas

assets.


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Safety Cases are also required from gas shippers, suppliers and storage operators. 2009 also saw

significant inroads made to develop and implement safety cases in many of these areas, with the

majority of shippers and suppliers now having an approved safety case.

Register of Gas Installers Ireland (RGII)

Under the 2006 Act, the CER designated the Register of Gas Installers of Ireland (RGII) as the Gas

Safety Supervisory Body (GSSB) to undertake the regulation of natural gas installers with respect

to safety on November 6th 2008. The process of registering gas installers began immediately, and

it subsequently became mandatory for any party wishing to carry out domestic gas work to be

registered (as a Register Gas Installer, or RGI) on the 26th June 2009. The CER worked closely with

the GSSB to ensure that all of the relevant protocols, procedures and agreements were developed

to facilitate and support this process.

The CER agreed with industry stakeholders to a transitional period where installers could join

‘provisionally’; the aim was to enable installers some time to register, obtain qualifications and

provide proof of indemnity. This period ended on 18th December 2009, with agreement that any

installers registered with the RGII at that date and undertaking a training course could finish the

course, within a reasonable timeframe.

At the end of 2009 there were 2,667 individuals registered as Registered Gas Installers operating

under the scheme. Also during 2009 the Bord Gáis inspectorate transferred to the new RGII and it

is the RGII who now carry out the inspection and audit program to ensure RGI’s are competent

and that their work meets the required national standard.


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In order to enforce the registration requirements 37 ‘cease and desist’ letters issued individuals

and companies operating outside of the RGII requirements. This is the first warning applied to

installers who are identified as not registered.

Gas Safety Promotion and Public Awareness

The CER Safety Division chairs and oversees an industry group (the Gas Safety Promotion and

Public Awareness Group) which is dedicated to the development and review of the national gas

safety promotion and public awareness activities. The activities of this group include all media

promotions, safety surveys, public awareness initiatives and promotions external to the industry.

The scope of activities includes areas such as:

• Utility damage prevention

• Carbon Monoxide

• Safe use of gas

• Gas escape awareness

• Register of Gas Installers

• Emergency preparedness and response

Past initiatives have included working with the Health Service Executive (HSE), Fáilte Ireland,

General Practitioners, Health & Safety Authority (HSA), ESB, Local Authorities, National

Standards Authority of Ireland (NSAI) and the Irish Liquefied Gas Association (ILPGA).

The objective of the Programme is to achieve the following 5 outcomes:

1. Increased levels of general public awareness of gas safety issues;


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2. Greater willingness among the general public to take preventative actions with respect to gas safety;

3. Greater willingness among the general public to take positive actions with respect to gas safety;

4. High levels of awareness of, and confidence in, the Register of Gas Installers amongst the general public and the installer industry; and

5. Raised levels of general awareness of the Commission’s role as the regulatory authority for gas safety matters in Ireland.

The year saw the development of a cohesive strategy for this process and the development of a

detailed programme of activity for 2010. This programme continues the existing advertising

activity and also currently seeks to develop awareness of the Register of Gas Installers and Carbon

Monoxide safety.

Gas Industry Reporting Regime

This annual gas safety report forms part of the evolving reporting strategy which has been

gradually implemented since the 2006 Act came into force. Criteria for the reporting and

investigation of gas incidents have been established for a number of years, however, inclusion of

this data in the wider reporting regime and the ability to utilise this data collectively with

undertakings’ reports, is a developing concept which enables the CER to obtain a fuller picture of

risk management. More significantly this permits the CER to make collective judgements and

positive interventions where necessary. It also determines the requirements for audits and

inspections which may be planned or sporadic in nature. All data is monitored continually and

reviewed quarterly to coincide with undertakings’ reporting frequencies. Gas Safety reports are

developed every quarter and presented by the Safety Division to the CER Commissioners.


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Framework Development Initiatives ‐ LPG

There is an ongoing iterative process for existing framework requirements requiring review and

consultation with natural gas undertakings. The 2006 Act made provision for the inclusion of

Liquefied Petroleum Gas (LPG) within the framework. However, it became clear on fuller analysis

that the legislative framework required further development to fully capture all relevant aspects of

the LPG supply chain which needed to be subjected to safety regulatory oversight by the CER.

Following a number of recent incidents involving LPG the need for this inclusion has been

accelerated and currently work is ongoing to fulfil this intention in close co‐operation with the

Department. The CER Safety Division published a consultation paper on 22nd May 2009 seeking

comment and recommendation on the safety regulation of the LPG industry. Following this

consultation a legislative consultation paper was published on the 4th February 2010 seeking views

on the proposed scope and delineation of responsibilities for the safety regulation of the LPG

industry, particularly with regard to the interface with safety legislation and the HSA. The

proposal seeks to address regulation of aspects of the LPG industry not currently encompassed by

existing legislation and includes:

• LPG installers and LPG installations with respect to domestic, commercial and

industrial premises;

• LPG distribution networks with respect to underground pipe systems (but not the

central LPG storage tank as this aspect is covered under Dangerous Substances

(Storage of Liquefied Petroleum Gas) Regulations 1990);

• LPG appliance related incident reporting in a domestic setting; and

• The need for statutory responsibilities to be placed on undertakings to promote

the safety of LPG customers and conduct LPG safety campaigns with respect to the

safe utlilisation of LPG.


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Natural Gas Safety Performance Report

The ongoing reporting and continuous improvement philosophy which underpins the Framework

has led to the formulation of a performance reporting process which provides information to

enable the CER to form a judgement on the performance, and ultimately the compliance, of

natural gas undertakings and supervisory bodies with the requirements of the Framework.

This reporting process is developing and incorporates learning and feedback from all parties

involved to provide Key Performance Indicators (KPI’s) of whether safety objectives are being

achieved. Data from undertakings’ reports, inspections, audits and incidents are reviewed and

remedial actions are addressed in consultation with affected groups. This information identifies

both corrective and preventative actions and learning forms the basis for audit and inspection

routines to provide assurance and any iterative improvements. Outcomes and actions are

regularly reviewed and the CER’s Safety Division reports trends and findings on a quarterly basis

to the Commissioners.

The format for reporting follows progress against the six key safety objectives and is continually

reviewed as the framework develops.


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2009 Incident Reporting Summary

There were four significant natural gas incidents during 2009, none of which caused serious injury

or fatality. The criteria for incident reporting has been established and operating for a number of

years with Bord Gáis Networks and operates around an agreed definition of reportable incidents.

The CER also has criteria for ‘non‐reportable’ gas incidents where, in the interests of learning, less

significant gas incidents are analysed and reviewed. The reportable incidents during 2009 may be

summarised as follows:

Damaged Gas Main at the Junction of

Dartmouth Place and Grand Parade

Dublin 10/01/2009

On 10th January 2009, employees of

Gerry McCloskey (GMC), a contractor

carrying out work on the Bord Gáis

distribution network in Dublin on behalf

of Bord Gáis Networks (BGN), damaged a 4 bar gas main with an excavator resulting in an

uncontrolled gas escape. The gas escape forced the closure of Grand Parade and the LUAS Green

line for approximately 3 hours and left three commercial buildings without gas. No‐one was

injured in the incident. The investigation revealed that the operatives were operating a

mechanical excavator in close proximity to the main. The CER Safety Division recommended that

Bord Gáis issue guidelines for working near buried plant and concrete. Since the incident

additional training has been completed. Precautions for working around buried concrete were

also issued.


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Explosion at 35 Temple Road, Blackrock, Co. Dublin 14/03/2009

An explosion occurred at around

lunchtime on the 14th March 2009, causing

considerable damage to three terraced

properties and minor injuries to occupants

and passers‐by. A number of motor

vehicles and surrounding properties were

also damaged. The subsequent

investigation identified that a fitting had been removed on the customers gas

installation near to the central heating boiler, leaving an open ended pipe to allow gas to

enter number 35, unburnt. The incident caused national media coverage and a

significant impact upon the local residents and businesses. A concurrent Garda

investigation was also carried out. No learning was identified from this incident.

Fire at 2 Donore Road, Dublin 19/12/2009

Bord Gáis responded to a fire adjacent to a

Decorative Flame Effect gas fire that had been left

unsupervised. The subsequent investigation

identified that the fire, installed c.1997, had never

been serviced and corrosion to three rivets had

allowed hot combustion gases to exit the fire

adjacent to combustible materials. No issues were

identified with the manufacture or installation of


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the fire. There were no injuries to the property occupants. This incident illustrates the importance

of regular and frequent servicing of gas appliances.

Boiler Fire at 11 Milltown Drive, Churchtown, Dublin 18/12/2009

The fire at the boiler caused broken windows, smoke

and heat damage around the boiler and on the first floor

landing. Investigation identified that the boiler had

been partially enclosed by a wooden partition. The

flueways of the boiler were heavily sooted causing the

hot combustion gases to exit through air intake

openings at the side of the boiler casing, directly onto

the flammable wooden partition. Interviews with the

property owner identified that the boiler had been

serviced some weeks prior to the incident. An

investigation by the Register of Gas Installers of Ireland

is continuing.

Incident Review

The CER also supported the National Consumer Agency (NCA) following two fatal incidents in

Macroom (21/11/2008) and Glenties (24/09/2009) involving Liquefied Petroleum Gas cooker grills.

The Safety Division supported extensive testing of appliances and a subsequent recall and

modification strategy for the appliances identified. The modification was to amend the full door

seal fitted on the cooker grill. This program is still progressing with more than 55% of all

identified appliances being modified or scrapped. Also, following a CER review and a campaign by


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Bord Gáis Networks, customers were warned of the potential risk of storing wheeled bins and

waste near to gas installations, following a number of malicious fires. Since implementation there

has been a significant reduction in the frequency of these fires.

Performance against Safety Objectives: 2009

Key Safety Objective 1: Minimising the Loss of Containment

Gas undertakings are required to demonstrate that they have suitable management systems and procedures in place for managing the risks that lead to loss of gas containment events occurring. Within the scope of this objective are:

• Gas escapes reported by the public.

• Damage to the gas transmission (high pressure) and distribution systems (lower pressure).

• Gas entry into buildings.

• Surveillance of works near pipelines.

• Corrosion protection and prevention.

Gas Escape Reports

Public reported gas escapes have gradually reduced over the last three years, and continue to

follow seasonal trends. Gas escapes frequencies are traditionally higher during cold periods due

to elevated mains pressures and the increased use of gas. Outside gas escapes reduced by around

10% on 2008 and internal escapes within customer’s premises reduced by around 5%.


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Figure 3: Public Reported Gas Escape Frequencies for 2009

Third Party Damage

There were no instances of third party damage to the gas transmission system during 2009. On

the distribution system there were 682 instances of damage, a reduction of 39% on the previous

year. Emphasis has been placed on hire companies and local authorities to develop a clearer

understanding of the appropriate methods to adopt to prevent damage to buried gas

infrastructure.

Figure 4: Third Party Damage Frequencies by Supply Pipe Type 2009

1,003 738 703 906

36382679 2277

3924

1278

937822

1427

01000200030004000500060007000

09 Q1 09 Q2 09 Q3 09 Q4

Breakdown of Public Reported Escapes

External No leak detected Internal

09 Q1 09 Q2 09 Q3 09 Q4

PE ‐ Mains 35 32 24 19

PE ‐ Services 142 181 142 107

020406080100120140160180200

Distribution ‐ Third Party Damages Breakdown


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Gas Entry into Buildings

There were no reported instances of gas entry into buildings from the Cast Iron gas network. This

indicator was developed to monitor the Cast Iron distribution system, prone to fracture causing

potential gas ingress into properties. The Cast Iron mains system has now been fully replaced with

plastic piping systems.

Pipeline Surveillance

The high pressure gas transmission system, constructed from high quality, welded steel, has strict

controls regarding third party works operating within close proximity. To avoid damage to

pipelines or their protective coatings, Bord Gáis Networks maintain a surveillance programme

with foot, vehicular and aerial surveys. During 2009 these activities identified and addressed 30

instances of such third party works. The CER identified a recurrent issue with respect to

agricultural drainage works, and so BGN will issue third party damage prevention guidelines to all

landowners with pipeline way leaves on their property during 2010.

Figure 5: Works identified near pipelines during 2009

0 0

967 6

1

1

0

2

4

6

8

10

12

Q1 09 Q2 09 Q3 09 Q4 09

Breakdown of Transmission Related Encroachment Events

Aerial Survey Encroachments/Event

Ground Patrol Encroachments/Events


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Pipeline Corrosion Protection

Bord Gáis Networks use a number of Cathodic Protection (CP) systems to prevent pipelines from

corroding and identify locations where pipeline coatings are breached or deteriorating. Previously

CP performance was monitored manually requiring field based staff to visit sites and take

readings. During 2009 Bord Gáis Networks have implemented a remote, electronic measurement

system for all monitoring points. The performance during 2009 has not been fully established due

to the introduction of a new continuous monitoring system.

Figure 6: Pipeline Cathodic Protection tests: planned vs actual

01002003004005006007008009001000110012001300

Q1 09 Q2 09 Q3 09 Q4 09

Transmission ‐ CP Tests

Pipe to soil potentials planned Pipe to soil potentials completed


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Key Safety Objective 2: Maintaining Safe System Operating Pressure

Gas undertakings are required to demonstrate that they have suitable management systems in place for managing the risks that can result in dangerously high or low gas operating pressure in the pipeline system(s). Within the scope of this objective are:

• Gas Outages

• Pressure Management and Control

Gas Outages

There were no gas outages on the transmission system during 2009. There were 9 reported

outages on the distribution system. This represented a reduction on this frequency during 2007

(15) & 2008 (10). The prime cause of outages is third party damage. All outages during 2009

affected less than 100 customers. Bord Gáis Networks have developed a new advice booklet issued

to third parties and are working with local authorities and plant hire companies to improve wider

industry awareness.

Figure 7: Unplanned Distribution Outages 2009

09 Q1 09 Q2 09 Q3 09 Q4

15 ‐ 99 5 2 0 2

100 ‐ 249 0 0 0 0

250 + 0 0 0 0

0

1

2

3

4

5

6

No. of Unplanned Dist. Outages by no. of customers


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System Pressure Management

Bord Gáis Networks operates a Supervisory Control and Data Acquisition (SCADA) system, which

monitors system pressures and alarms when defined parameters are exceeded. There were no

issues identified with the gas transmission system during 2009. There were 43 alarms for

over/under pressure events on the distribution system, indicating an increase on levels

experienced during 2007/8. These alarms may indicate a number of causes from a pressure

fluctuation requiring no operational intervention to a gas outage. The increase during 2009 was

largely due to software issues and new high demand supplies being added. This gives a false

reading as only the immediate pipe system experiences a pressure drop.

Figure 8: Frequency of system pressure drops on the distribution system

Q1 09 Q2 09 Q3 09 Q4 09

Dist. 9 16 2 3

Trans. 0 0 0 0

024681012141618

Freq

uency of occuren

ce

Frequency of System Pressure Drops


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Key Safety Objective 3: Minimising the risk of injecting gas of non‐conforming quality

Gas emergency incidents can arise due to gas of inappropriate quality being injected into the system and, as such, gas undertakings are required to demonstrate that they have suitable management systems in place for gas quality monitoring and managing the risks associated with the quality of gas that is injected into the system.

The KPIs for this objective are:

• Odorant; and • Gas Quality.

Odorant Management

In order to identify uncontrolled leaking gas, gas has an odour added to, which must be

maintained within prescribed limits to be detected by the human nose. There were three non‐

compliant test results identified during 2009. This was a significant improvement on 20 identified

during 2008. Most of these issues were associated with new pipelines with minimal or no flow,

where the odorant ‘falls out’ of the gas stream. This requires local injection to rebalance the levels

of odorant.

Gas Quality

Ensuring gas quality remains within a prescribed range is critical to ensure that gas supply

remains safe. An example would be where the heat value (Calorific Value) fluctuates causing an

increased risk of carbon monoxide at the appliance. There were no issues identified with gas

quality during 2009.


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Safety Objective 4: Providing an Efficient and Coordinated Response to Gas Emergencies

This Objective 4 states:

Gas emergency events occur due to insufficient supplies into the network or a transportation constraint, including the actions of third parties. Gaslink is required to demonstrate that it has suitable arrangements in place for: (i) managing the response to ‘localised’ gas emergencies; and (ii) undertaking the role of National Gas Emergency Manager during ‘network’ gas emergencies. Additionally, all gas undertakings are required to demonstrate that they have suitable arrangements in place for responding to the requirements of the National Gas Emergency Manager in the event of large‐scale ‘network’ gas emergencies occurring.

The KPIs for this regulatory objective, which are discussed in Sections 4.4.1 to 4.4.2, are:

• Gas Supply Emergencies; and • Public Reported Escapes.

Gas Supply Emergencies

There were no gas supply emergencies during 2009 that required initiation of the National Gas

Emergency Plan (NGEP). This plan was recently developed and authorised by the CER, and

outlines the management principles for addressing a large scale gas supply emergency affecting

gas supplies and electricity generation. Bord Gáis Networks undertook two exercises during the

year; the first focussed on crisis management of a combined transmission and distribution

emergency; the second was a simulated site based exercise involving the loss of supply to Dundalk

and approx. 5,000 customers.

Public reported Gas Escapes

Bord Gáis are required to respond to all reported escapes of gas within 1 hour. There were 20,332

Public Reported Escapes in 2009 with 17 responded to outside of the 1 hour response criterion,

making the response 99.92% compliant. The majority of these late arrivals were due to adverse


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weather conditions, particularly flooding and snow which may impede the response speed. Bord

Gáis are required to respond to all gas escapes within 1 hour where possible.

Figure 9: Gas Escape Response Efficiency by quarter 2009

99.92% 100.00% 100.00% 99.81%

0.00%

20.00%

40.00%

60.00%

80.00%

100.00%

09 Q1 09 Q2 09 Q3 09 Q4

% Public Reported Escapes Attended < 1 Hour


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Safety Objective 5: Minimising the Safety Risks Associated with the Utilisation of Gas

Regulatory Objective 5 states:

The key aim of this regime is that all categories of ‘gas works’ designated by the Commission are only undertaken by competent gas installers who are registered, and subject to ongoing regulation and inspection, by the GSSB appointed by the Commission. The connection and re‐connection of customers’ installations to the gas supply network and the servicing of such installations are important safety risk issues that will be addressed within the scope of this objective. Customer education and safety awareness is an important part of this gas safety objective as discussed in key objective 6.

The KPIs for this regulatory objective are:

• Registered Gas Installers and the Regulatory Scheme;

• Installation Statistics;

• Meters;

• Carbon Monoxide;

• Disconnections; and

• Incidents (Downstream of the meter).

Registered Gas Installers and the Regulatory Scheme

The CER embarked on an extensive promotional campaign during the implementation of the Gas

Safety Supervisory Body which included national and local press, communication to industry

parties and Installer Road Shows. The number registered on the scheme by the end of 2009 was

2,667 Registered Gas Installers. The scheme allowed for trainee, provisional and full membership

categories, with the provisional membership category being phased out over the space of the year

through training and development requirements. The competence of individual installers is


32 | P a g e

affirmed not only at entry level to the scheme, but also through an ongoing inspection process

which began when the requirement for registration became mandatory in June 2009. The

inspectors codify their work with respect to the level of risk observed, and remedial actions are in

accordance with the level of finding. During the two quarters only one severe defect was

identified, associated with the incident at 11 Milltown Drive, Churchtown, Dublin. Once this

defect was identified, the Registered Gas Installer involved was automatically subject to a

Disciplinary Hearing. The outcome of that hearing resulted in the Registered Gas Installer

requiring further inspection by the RGII, the cost of which will be borne by the Registered Gas

Installer. Although the data set is still in its infancy, early indications confirm a higher incidence

of faults with provisional members and a high rate of faults on industrial/commercial works.

Figure 10: Registered Gas Installers by Class of Membership 2009

Q1 09 Q2 09 Q3 09 Q4 09

Trainee 0 91 83 87

Provisional 121 511 390 351

Full 641 1834 2043 2229

0

500

1000

1500

2000

2500

3000Number of RGIs by Membership Class


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Installation Statistics

When a Registered Gas Installer performs an item of work (new installation, replacement or

servicing) a completion certificate should be completed and a copy returned to the GSSB. During

the last 2 quarters of 2009 the RGII received 51,604 appliance servicing certificates, 1,283 appliance

replacement certificates and 2,242 new gas installation certificates1. It is anticipated that this

figure will rise as installers grow accustomed to the new scheme. Internal gas escapes have

reduced year on year since 2007, however hazards identified by Bord Gáis Networks when visiting

properties has slightly increased. This statistical trend will be closely monitored to identify

learning or performance improvements.

Meters

Meter performance is gauged by monitoring frequencies of faulty or tampered meters. During

2009 there were 55 reports of meter tampering. It is expected that this statistic will reduce with

ongoing meter replacement, smart metering and continuing vigilance within Bord Gáis. Bord Gáis

Networks identified 5,336 faulty meters during 2009. Issues regarding the ageing meter

population are currently being assessed. Faults may include leaks, noise and reading inaccuracy.

Figure 11: Numbers of tampered meters identified during 2009

25

8

1210

0

5

10

15

20

25

30

09 Q1 09 Q2 09 Q3 09 Q4

No. of Tampered meters identified


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Figure 12: Numbers of meter leaks or faults identified during 2009

Carbon Monoxide

The predominant measures for Carbon Monoxide are largely applied to develop the public

perception with respect to the dangers of Carbon Monoxide. The effectiveness of Carbon

Monoxide campaigns are measured through customer surveys and customer safety enquiries.

The Safety Division has developed a Carbon Monoxide strategy for the future. The purpose is to

develop the scope, application and measurement of Carbon Monoxide related activities.

Specifically, this strategy seeks to develop existing technologies including Carbon Monoxide

alarms whilst increasing the scope of strategic influence to all fossil fuel types, including coal, oil,

wood and LPG. Bord Gáis Networks provide a free Carbon Monoxide safety check service to

customers who may have concerns regarding their gas installation, but with no cause to suspect

immediate danger. 2009 saw an increase of 30% in these enquires. Also during 2009 Ipsos MRBI

conducted random interviews with a sample of 1,000 adults and determined that awareness of

Carbon Monoxide dangers had risen by 4 points to 91%.

1645

13061152

1233

0200400600800

10001200140016001800

09 Q1 09 Q2 09 Q3 09 Q4

No. of Faulty or Leaky Meters identified


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Figure 13: Number of customer requested safety checks performed during 2009

Safety Disconnections

Bord Gáis Networks carry out safety disconnections where it has been identified that an unsafe

situation exists on a customer’s gas installation. The frequency of these disconnections has

reduced steadily from a high of 630 at the end of 2007 to 386 at the end of 2009, a 39%

improvement.

08 Q1 08 Q2 08 Q3 08 Q4 09 Q1 09 Q2 09 Q3 Q4

CO Safety Checks 125 80 70 102 188 109 74 166

125

8070

102

188

109

74

166

0

20

40

60

80

100

120

140

160

180

200

Number of CO Safety Checks since 2008


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Figure 14: Bord Gáis Networks Safety Disconnections during 2009

Incidents Downstream of the Meter

Analysis of the 3 incidents occurring on the customer’s gas installation identified one failure due

to a malicious act and 2 incidents arising from poor or absent appliance servicing. The current

safety campaigns emphasise the need to service appliances regularly, and to only use a Registered

Gas Installer. The programme for 2010 intends to further emphasise this message through TV,

radio and written media.

07 Q1 07 Q2 07 Q3 07 Q4 08 Q1 08 Q2 08 Q3 08 Q4 09 Q1 09 Q2 09 Q3 Q4

Safety Disconnections 406 429 537 630 491 486 482 474 448 444 416 386

0

100

200

300

400

500

600

700

Total Number of Safety Disconnections (since '07)


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Figure 15: Incidents occurring on the customer’s side of the gas meter during 2009

Key to Incident Types

Type A: Concerns an incident where loss of life has been experienced

Type B: An incident where an injury has been sustained requiring overnight hospitalisation as a

minimum

Type C: An incident where property damage exceeds an estimated value of €6,350

0

1

2

3

4

Q1'07 Q2 '07 Q3 '07 Q4 '07 Q1 '08 Q2 '08 Q3 '08 Q4 '08 Q1 '09 Q2 '09 Q3 '09 Q4 '09

Breakdown of Incidents ‐ Downstream of the Meter

Type A Type B Type C


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Safety Objective 6: Promoting Public Awareness of Gas Safety

Regulatory Objective 6 states:

Increasing the level of gas safety awareness amongst gas customers and the public generally

and, in particular, educating on the dangers of carbon monoxide is an important aspect of the

Commission’s overall objective of promoting the safety of customers and the general public in

respect of the use of gas. It will also be important that owners/occupiers of premises are aware of

their responsibilities in respect to the maintenance of gas fittings downstream of the meter. The

proposed gas safety framework places duties and obligations on both individual gas undertakings

and the industry generally for the promotion of gas safety awareness. This will involve a

combination of both individual and co‐ordinated safety promotional activities by undertakings.

The currently identified KPIs for this regulatory objective are:

• BGN Emergency Number Calls • Carbon Monoxide Reports and website visits • Dial‐Before‐You‐Dig Calls • RGII website visits

Emergency Number Calls

The frequency of calls to the 1850 205050 number is indicative of the public awareness of the

number and its function. The number of calls to this number was 75,632 with confirmed gas

escapes in 27% of cases. During 2008 there were 53,514 calls with escapes confirmed in 35% of

cases. The high degree of non‐emergency calls has been attributed to the emergency number

being prominently displayed on bills and other literature and therefore confirms customer


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awareness; however Bord Gáis Networks intend to review this promotion to ensure that

customers are aware of the purpose of the number.

Figure 16: Frequency of enquiries to the BGN emergency number vs actual reported gas escapes

Carbon Monoxide Calls and Website Activity

Calls and website hits remained seasonal in nature and aligned to advertising bursts. There were

5,178 unique website visits and 2,487 calls to the Carbon Monoxide help number during 2009.

09 Q1 09 Q2 09 Q3 09 Q4

Calls to Emergency Number 20623 17892 15589 21528

Total PREs 5919 4354 3802 6257

0

5000

10000

15000

20000

25000

Calls to Emergency Number 1850 20 50 50


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Figure 17: Numbers of CO Enquiries

Dial Before You Dig

The dial before you dig process is designed to provide third parties with safety advice and

planning material before they excavate. The majority of enquiries regarded distribution pipe

locations (90%) with a total of 5,270 enquiries received during 2009.

Figure 18: Plant location enquires to the dial before you dig line

09 Q1 09 Q2 09 Q3 09 Q4

CO Website Visits 1923 724 655 1876

Calls to CO Number 899 339 365 824

0

500

1000

1500

2000

2500

Number of Calls to CO Helpline and Vistis to CO Website

12521382 1404

1232

0

200

400

600

800

1000

1200

1400

1600

09 Q1 09 Q2 09 Q3 09 Q4

Total number of Enquires to DBYD Number


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RGII Awareness

The Gas Safety Supervisory Body website is a prime mechanism for customers wishing to find a

registered gas installer and this has been advertised through a range of media. This is a new

process so no comparative data exists. Since the scheme was launched at the end of June 2009,

there have been 25,791 visits to the website during 2009.

Recognition of the Registered Gas Installer scheme has increased significantly during the last

6 months of 2009. A survey carried out by Bord Gas in 2008 highlighted that the awareness of the

scheme, at that time, by the public was at 17%, however following a coordinated media campaign

by Bord Gas and the CER that figure has risen to 38% for natural gas customers and 35% for the

general public. This is an encouraging statistic that will continue to be monitored.

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Compliance Summary Report

The Framework itself, and all the detailed regulatory documents which stem from it, represent

the standard for compliance against which each undertaking and the GSSB are measured.

Specifically this includes measuring compliance with:

• The 2006 Act; • The Natural Gas Safety Regulatory Framework; • The Safety Case Guidelines, and individual Safety Cases with respect to each

undertaking; and • The Terms and Conditions of Appointment and the Criteria Document with respect to

the RGII.

Compliance with the Framework is largely assessed through a comprehensive Audit and

Inspection regime. This consists of a recurrent 3 year Audit & Inspection Programme from 2009 –

2011 which comprises of three distinct components:

1. A triennial in‐depth audit of each individual undertaking and the GSSB; 2. Ongoing audits & inspections as per structured and undertaking/GSSB specific Annual

Audit & Inspection Plans. This component is the core of the Audit & Inspection Programme; and

3. Ad hoc audit & inspection which are undertaken on an as needed basis.

Compliance Summary:

On the basis of the audits and inspections undertaken, and the analysis of the compliance monitors, it is reasonable to surmise that Transmission and Distribution undertakings are operating in compliance with their accepted Safety Cases. The GSSB is inspecting the work of Registered Gas Installers in line with the frequency set out in the Criteria Document. Overall the Framework is currently achieving the desired safety outcomes, however this cannot be ratified until the framework is fully implemented and a full audit, reporting, evaluation and inspection process exists.

Natural Gas Safety Report to - CRU Ireland

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