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1 AGA Distribution and Transmission Engineering Committee Open Forum 40 Note: The survey responses are based on an informal survey and are for general information only. They are not intended to bind any company or state a company's official position. The information represents an unaudited compilation of information and could contain coding or processing errors. Anyone using this document should rely on his or her own independent judgment or, as appropriate, seek the advice of a competent professional. References to work practices, products or vendors do not imply an opinion or endorsement by AGA or a responding company. This publication is confidential and proprietary to AGA. AGA Full and Limited Members are granted a limited license to reproduce this publication for internal business purposes but not for regulatory or civil matters. This document is not intended to provide legal advice or opinions. As always, you should consult your legal counsel for advice based on the law and your company’s specific facts and circumstances. Copyright & Distribution: Copyright © 2011 American Gas Association. All rights reserved. This work may not be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording, or by information storage and retrieval system without permission in writing from the American Gas Association. Q&A Alabama Gas Corporation Bob Gardner 1. What criteria do you use to determine when to install pipe by trenching vs. directional bore? AGL Resources: New construction and renewal projects are bid out to contractors where it is generally determined by the contractor as to preference, terrain, and cost effectiveness. Alabama Gas: Depends on the site conditions, including soil type, developer preference, and conflicts with other utilities, permitting restrictions. Citizens Gas: Primarily determined by overall cost which would be influence by restoration cost. We’ll do more boring in established areas and where there numerous driveways Consumers: We prefer to trench, but evaluate bore depending on the number of obstacles, such as driveways, trees, other facilities (water, electric, sewer). Enbridge: Constructability / Cost line location/offsets (bends), length, depth, proximity to other utilities, volume/location of laterals (service & main), restoration, soil conditions, situations where open trench is not an option i.e. rail & river crossings, surface elevations that will not be conducive to open trenching. National Grid: We have captured cost data on pipe installation projects for several years. We have developed matrix for pipe size, road strata, and region. This is used as the first cut at determining installation method. Once a work package is give to the field forces, the supervisor can modify the installation method based on specific work site conditions. NJ Natural Gas: Use of directional drilling for us is typically driven by restoration requirements. We would typically look to use it when installing main behind the curb instead of going in the pavement and completing extensive roadway repairs. We also drill whenever possible when crossing major roads and on bridges/culverts when right-of-way is available. PECO: No formal criteria, each job is reviewed specifically for installation method. Some things that will push decision from direction drilling are: number of buried facility crossings, ground/soil conditions, and number of gas services to be moved to new main.

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Page 1: AGA Distribution and Transmission Engineering Committee ... › sites › default › files › legacy... · MDPE plastic pipe for IP projects and would install steel pipeline if

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AGA Distribution and Transmission Engineering Committee Open Forum 40

Note: The survey responses are based on an informal survey and are for general information only. They are not intended to bind any company or state a company's official position. The information represents an unaudited compilation of information and could contain coding or processing errors. Anyone using this

document should rely on his or her own independent judgment or, as appropriate, seek the advice of a

competent professional. References to work practices, products or vendors do not imply an opinion or endorsement by AGA or a responding company. This publication is confidential and proprietary to AGA. AGA

Full and Limited Members are granted a limited license to reproduce this publication for internal business purposes but not for regulatory or civil matters. This document is not intended to provide legal advice or

opinions. As always, you should consult your legal counsel for advice based on the law and your company’s

specific facts and circumstances.

Copyright & Distribution: Copyright © 2011 American Gas Association. All rights reserved. This work may not be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying,

recording, or by information storage and retrieval system without permission in writing from the American Gas Association.

Q&A

Alabama Gas Corporation – Bob Gardner

1. What criteria do you use to determine when to install pipe by trenching vs. directional bore?

AGL Resources: New construction and renewal projects are bid out to contractors where it is generally

determined by the contractor as to preference, terrain, and cost effectiveness.

Alabama Gas: Depends on the site conditions, including soil type, developer preference, and conflicts with other utilities, permitting restrictions.

Citizens Gas: Primarily determined by overall cost which would be influence by restoration cost. We’ll do more boring in established areas and where there numerous driveways

Consumers: We prefer to trench, but evaluate bore depending on the number of obstacles, such as driveways, trees, other facilities (water, electric, sewer).

Enbridge: Constructability / Cost – line location/offsets (bends), length, depth, proximity to other

utilities, volume/location of laterals (service & main), restoration, soil conditions, situations where open trench is not an option i.e. – rail & river crossings, surface elevations that will not be conducive to open trenching.

National Grid: We have captured cost data on pipe installation projects for several years. We have

developed matrix for pipe size, road strata, and region. This is used as the first cut at determining installation method. Once a work package is give to the field forces, the supervisor can modify the installation method based on specific work site conditions.

NJ Natural Gas: Use of directional drilling for us is typically driven by restoration requirements. We

would typically look to use it when installing main behind the curb instead of going in the pavement and completing extensive roadway repairs. We also drill whenever possible when crossing major roads and on bridges/culverts when right-of-way is available.

PECO: No formal criteria, each job is reviewed specifically for installation method. Some things that will push decision from direction drilling are: number of buried facility crossings, ground/soil conditions, and number of gas services to be moved to new main.

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PG&E: The following criteria are considered; number of substructures in the area, soil conditions, paving requirements, local governmental agency requirements, cost/economics.

Philadelphia Gas: We rarely use directional bore. For short stretches, a rail road siding for instance, jacking

may be used.

Puget: Some or all of the criteria may be used: suitability of the soil for directional boring, feasibility of stopping or re-routing surface features (ex: size of stream or river), cost of hard surface restoration, physical space available for a drill string, permit restrictions, run-off considerations, soil contamination, and availability and cost of materials and fabrication.

Southwest Gas: Directional boring will be used to avoid cutting “no-cut” pavement like highways or to

install below large sub-structures such as concrete channels. In other situations the determination is made case by case.

Washington Gas: Job site conditions, soil conditions, permit restrictions and conditions, easement and

right way conditions, state and local regulatory requirements, construction costs - trench vs drill - , and size/type of pipe are all taken into consideration.

We Energies: Restoration requirements and costs, environmental areas such as wetlands, waterways, burial grounds, etc. Trenching is usually the default option if feasible due to lowest cost.

2. Under what operational circumstances or conditions, do you specify plastic mechanical fittings vs. fusion fittings?

AGL Resources: Company policy is generally to use heat applied fusion in most cases and where heat applied fusion is not practical, electrofusion is the next preference. Mechanical fittings are generally used as a last resort. However, exceptions to this policy is the use of stab type fittings used for quick repairs for damages.

Alabama Gas: Mechanical fittings more frequent on repair or replacement, fusion fittings on new installations, but no specific criteria in place for use of either type

Citizens Gas: We primarily use Lycofit on repairs 2” and smaller and Electrofusion on 3” and larger

Consumers: We use fusion 100%.

Enbridge: We do not use plastic mechanical fittings

National Grid: PE fusion fittings are used on pressure system operating above 99 PSIG & below 125 psig.

NJ Natural Gas: Fusion fittings are preferred and specified for use in almost all cases (when direct butt fusion cannot be done.) We only allow our forces to use mechanical fittings for emergency repairs.

PECO: Plastic mechanical fittings are no longer used on system. PG&E: Mechanical fittings (up to 2” IPS) are used to facilitate plastic connections when typical

heat-iron or electro-fusion is not practical due to the need for generators, processors, irons, cooling time, etc.

Philadelphia Gas: Tie-ins, service lines

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Puget: The use of mechanical fittings versus fusion fittings is primarily based on size. Bolt-on tees are available in 1-1/4" and 2" pipe sizes and are typically only used for new construction mains and services in plat developments. In-line mechanical compression fittings are used for 1/2" and 1" CTS service piping. All other MDPE installations incorporate fusion fittings and fusion service tees.

Southwest Gas: Mechanical fittings are generally used at PE tie-ins because of issues related to fusing new PE to older PE.

Washington Gas: We do not specify mechanical vs fusion.

We Energies: We prefer to use fusion fittings wherever possible and only use plastic mechanical fittings under special circumstances like main or service repairs on non-fusable pipe or where hydrocarbon permeation exists.

3. Do you install HDPE on jobs where steel might otherwise be specified? What is your criteria (operational circumstances/conditions) for using HDPE?

AGL Resources: HDPE is generally not used within the Company’s distribution system. However, we are

currently installing HDPE on a landfill project that will be an isolated system to an industrial customer.

Alabama Gas: Limited use of HDPE. No established criteria but used when application is suitable.

Citizens Gas: We don’t install HDPE but we do install MDPE and the steel vs plastic decision is based on average installed cost.

Consumers: No, we do not use high density plastic pipe.

Enbridge: Yes. 12” diameter only. 60 psig and 100psig systems including landfill gas.

National Grid: All new gas main projects on distribution system up to and including 12” are installed using PE material operating 100 PSIG & below unless the internal diameter of the PE pipe causes too much of a pressure drop. Then steel is used.

NJ Natural Gas: We use HDPE for all installations up to 60 psig. Steel is typically only used on exposed

bridge crossings, or on short steel section replacements when the existing steel is on a rectifier.

PECO: Yes – HDPE is used up to 6”. Above that size, steel is used. HDPE will be used unless there is a reason that plastic cannot be used, i.e. hydrocarbon contamination.

PG&E: No. We do not use HDPE.

Philadelphia Gas: No. We use MDPE.

Puget: No. PSE would not substitute HDPE for steel pipeline applications. PSE only installs MDPE plastic pipe for IP projects and would install steel pipeline if an alternative pipe materials was needed for operational circumstances/conditions (i.e. high pressure, close to steam lines, aboveground piping, etc.).

Southwest Gas: No.

Washington Gas: No. We have installed 12” HDPE pipe instead of the 12” MDPE pipe due to its superior mechanical properties.

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We Energies: Our standard material for 8” plastic is PE100/4710 (a type of high density plastic). All other sizes of plastic use medium density plastic. We use PE100 versus steel when installing 8” wherever possible due to the reduced cost. (PE100 is more expensive than medium density PE pipe). All of our plastic pipe currently operates at 60 psig or less.

4. Do your degreed engineers function as designers and project managers or just designers?

AGL Resources: Agree that engineers should function as both designers and project managers.

Alabama Gas: Presently function in design review and compliance

Citizens Gas: Design and project management is performed by both degreed and non-degreed

personnel depending on the complexity of the job and whether it’s transmission or distribution.

Consumers: Our degreed engineers function as both designers and project managers in both transmission and distribution.

Enbridge: Our degreed engineers do design work, project management and take on traditional management roles.

National Grid: Both

NJ Natural Gas: Our engineers do all aspects of their projects.

PECO: Just as project managers. PG&E: For gas distribution, degreed engineers typically do not prepared detailed designs, this

is done by gas estimators. Engineers provide technical guidance and mentoring of estimators. These engineers also project manage smaller jobs (less than $100k). For gas transmission, our gas engineers are responsible for both project designs and project management for projects < $1million. For projects > $1 million, project management responsibilities are typically assigned to dedicated Project Managers.

Philadelphia Gas: Depending on their level of experience (Eng I, II, III, Staff, and Senior Staff Engineer)

our degreed engineers can function as Operations Supervisors/ Managers, Project Managers and Designers.

Puget: In general the degreed engineers serve in a design capacity only, although there are

small aspects of project management in every engineer’s area of responsibility. Project management is a separate job description, although it is entirely possible that a degreed engineer can be hired into a project management position.

Southwest Gas: Engineers will operate as both designers and project managers. Typically, work will be

handed off to the Construction group after the final design and permitting is complete, but will still include the engineer if there are issues/conflicts in the field. Larger projects will see engineers involved in project planning and execution even after it has been handed off to the Construction group.

Washington Gas: Both designers and project managers.

We Energies: Degreed engineers do both but do more review and approval of designs that are completed by our “Designers”. Our “Designers” are typically represented employees whose main job is to complete the design for main and service projects.

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National Grid – Eric Aprigliano

The following questions pertain to handling of steel traffic plate safety:

5. What types of equipment does your company use to transport plates from the storage yards to the job site?

AGL Resources: Crane trucks

Alabama Gas: Truck/trailer and backhoe

Citizens Gas: Hydralift or Plate Truck (Boom Truck).

Consumers: We use standard flatbed trailer to transport and an excavating trencher to lift and place.

Enbridge: Typically a flatbed “crane” truck or tag along trailer

National Grid: Plate truck & dump truck.

NJ Natural Gas: We typically do not use steel plating. On rare occasions, it is our contractors who use and transport.

PECO: Boom Truck PG&E: When using Company owned steel plates, employees haul the plates using a flat bed

trailer or flat bed boom truck.

Philadelphia Gas: Flatbed trailer truck

Southwest Gas: This is mostly contracted out, but if it is required a flat bed backhoe trailer is utilized.

Washington Gas: Flat bed boom/crane truck/trailer.

We Energies: Typically dump trucks and/or trailers.

6. Do you use a single point or double points for lifting plates?

AGL Resources: Double points

Alabama Gas: Double

Citizens Gas: Single point

Consumers: Double points.

Enbridge: Single

National Grid: Standardized double points for lifting for plates recently.

NJ Natural Gas: Double

PECO: Single point PG&E: We utilize single points for lifting plates with various styles of lifting eyes.

Philadelphia Gas: Double points

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Southwest Gas: Depending on the size of the plate, larger plates use a double point, but both single and double are used.

Washington Gas: Single point.

We Energies: It depends on the size of the plate.

7. Does the steel plate handling is a single man or two man operation?

AGL Resources: single man

Alabama Gas: two man

Citizens Gas: Two person operation but the second person is usually from the crew on site.

Consumers: Two or more men are used in steel plate handling.

Enbridge: Minimum Two person

National Grid: In some region it is a two man operation and some single man operation.

NJ Natural Gas: Two man.

PECO: Most cases it is a single man operation PG&E: When we are setting the plates or stacking the plates we will use 2 people, one

operating the equipment and the other guiding the plate with the magnetic steel plate handling tool.

Philadelphia Gas: It’s a two man operation

Southwest Gas: In areas of high traffic congestion two men are utilized for safety, otherwise a one man

operation is used.

Washington Gas: Two (One Machine Operator & One Laborer)

We Energies: Two man.

8. Does your company procedure require use of a tag line when loading and unloading steel plates from the

vehicle?

AGL Resources: There is no formal procedure in place, but a tag line is used in most cases.

Alabama Gas: No

Citizens Gas: No.

Consumers: Our procedure recommends the use of a tag line when possible, but doesn’t specifically address steel plates.

Enbridge: Yes - Must also adhere to O&M 2.5.13 Hoisting Equipment Safety

National Grid: Use of tag line is dictated by specific site situation

NJ Natural Gas: n/a

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PECO: Not required, but available if needed PG&E: No. We do not require a tag line but once the steel plate is within reach of the ground a

second employee on the ground will utilize a steel plate magnet to control the plate.

Philadelphia Gas: Yes

Southwest Gas: Yes

Washington Gas: No.

We Energies: Not that we know of.

9. Do you require coating of steel plate on one side to prevent skidding?

AGL Resources: No

Alabama Gas:

no

Citizens Gas: No.

Consumers: No, we do not require coating.

Enbridge: Yes – non skid surface

National Grid: In New York city DOT requires antiskid coating. Other regions do not require coating on plates.

NJ Natural Gas: No

PECO: No PG&E: Depends. We typically will require coated steel plates especially in the city work. If we

are working on a road way without pedestrian right of way we may utilize non coated steel plates..

Philadelphia Gas: No

Southwest Gas: No

Washington Gas: No.

We Energies: No.

10. What types of lifting equipment such as alloy chain, nylon sling or wire rope you use for plate lifting?

AGL Resources: Nylon Sling

Alabama Gas: Chain

Citizens Gas: Chain or Nylon sling Consumers: We use a sling or chain rated for lifting. Enbridge: Alloy chain assembly

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National Grid: Alloy chain & nylon sling

NJ Natural Gas: Sling

PECO: Nylon sling only PG&E: We utilize steel chains to lift the steel plates.

Philadelphia Gas: Wire rope

Southwest Gas: Chains are used.

Washington Gas: Nylon sling/chain.

We Energies: Steel chains are used for plate lifting.

11. Do you have a company policy or practice for plate installation and securing in roadway?

AGL Resources: No formal policy or practices are currently in place

Alabama Gas: no

Citizens Gas: We have a procedure for pinning plates. Consumers: No, we have no company policy. Enbridge: Yes – O&M 2.25.2

National Grid: Yes

NJ Natural Gas: No

PECO: Yes a construction standard PG&E: No. Depending on site conditions, crews may utilize railroad spikes driven into the

pavement around the plate to prevent slipping especially in heavy traffic areas. We will sometime countersink the plates but this is typically a permit condition when we do this.

Philadelphia Gas: Yes Southwest Gas: Yes and also per requirement of the permitting agency.

Washington Gas: Yes. The plate installation practice includes at the minimum, an adequate number of

pins to prevent any type of plate movement, and temporary paving around the edges of the plate. Milling of the pavement in order to recess the plate into the road surface may be necessary in certain situations.

We Energies: The plate is to be pinned in four corners if in the roadway.

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New Jersey Natural Gas – John Wyckoff

12. What type of corrosion application does your company use on transmission pipeline girth welds and fittings (i.e. shrink sleeves, spray epoxy, tape, etc.), and what products are available for this purpose? Do you use a

different method for steel distribution, and if so, what?

AGL Resources: A two part epoxy liquid is generally used, however, When the use of a two-part epoxy

is impractical, shrink sleeves or cold applied tapes are used. However, neither shrink sleeves nor tapes are used on piping that is to be bored, driven, or mechanically installed without prior approval.

Alabama Gas: Various kinds: mostly tape, some mastic, some shrink sleeves Use the same for steel distribution

Citizens Gas: Two part epoxy, Denso protal

Consumers: We use epoxy, hot tape and wax for both transmission and distribution.

Enbridge: Transmission pipelines – Specialty Polymer Coating SP 2888 (brush applied – two-part epoxy). Distribution pipelines – Tapecoat 20 or shrink sleeve (HDD), Tapecoat T-tape (trenching)

National Grid: The Company standard allows the use of Two Part Epoxy, Shrink Sleeves, Cold Applied Tapes and Wax Tape (wet conditions). There are various good products on the market. Distribution pipe girth welds and fittings are coated with Shrink Sleeves, Cold Applied Tapes and Wax Tape (wet conditions).

NJ Natural Gas: We use RayChem shrink sleeves for girth welds, Dirax sleeves on directional drill welds, and Polyken tape/shrink sleeve combo on fittings. Same on distribution for 12” and above, tape on smaller sizes. In our operational experience, we have found that the shrink sleeves can be time-consuming and on occasion are prone to installation error. We are are looking for alternatives to reduce these.

PECO: Newer transmission construction has been shrink sleeves. Distribution is primarily tape coated – although shrink sleeves are used for directional drilling.

PG&E: We have a number of approved coatings in the following order based on multiple

factors and our field experience. Employees are advised to apply highest coating on the approved coating list that can be applied consistent with the field conditions and taking into account economic factors. The list of approved coatings is as follows: Fusion Bond Epoxy Protal 7200 (epoxy) Powercrete J ( epoxy) Devgrip 238 ( epoxy) Wax Tape Polyethylene tape The use of other coatings such as shrink sleeves and ARC is only approved for piping that will be subjected to the abrasion associated with boring operations. The coatings listed above are the only approved coatings for both buried transmission and buried distribution piping.

Philadelphia Gas: Polyken primer and Polyken tape or wax tape primer and tape

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Puget: For girth welds and fittings on transmission pipelines, liquid epoxy would be used for belowground piping and UV pipe tape and/or thermoplastic powder coating would be used for aboveground piping. Belowground girth welds and fittings on distribution pipeline would be covered with liquid epoxy, cold applied tape or wax tape. Aboveground would typically be protected with UV tape or a thermoplastic powder coating. Shrink sleeves would be used on both transmission and distribution pipelines for horizontal directional drill (HDD) applications.

Southwest Gas: For girth welds on both transmission and distribution we use shrink sleeves, spray or

field applied epoxy or tape wrap. Which one is used is usually based on the soil conditions and to some extent the cost. Shrink sleeves are procured from Canusa, spray epoxy from Canusa or Tyco Adhesives and tapes are Polykin, Polyguard or VISCOTAQ which are all product names. For fittings we use grease wrap manufactured by Trenton.

Washington Gas: We use shrink sleeves for girth welds. We use hot wax for fittings.

We Energies: We may either use epoxy coatings or cold applied tap coatings for transmission line and distribution girth welds.

13. What is your company's policy or practice of recording transmission line hydro-tests (i.e. dead weight, electronic recorder)? If electronic, what is its make/model?

AGL Resources: Dead Weight

Alabama Gas: Battery Chart Recorders

Citizens Gas: Dead weight but we are looking at electronic recorders.

Consumers: We use a dead weight and a chart recorder, not electronic.

Enbridge: Electronic – Crystal Model 33

National Grid: All transmission main is Hydrostatically tested prior to installation using both a hydraulic dead weight tester ( Refinery Supply )and a battery operated chart recorder ( Mercury)

NJ Natural Gas: We currently use a dead weight tester.

PECO: Dead weight PG&E: We allow the use of either a dead weight tester or electronic recorder for hydrotesting.

Philadelphia Gas: Dead weight tester with temperature recorder. Record pressure readings at 30 minute

intervals.

Puget: Transmission hydro-tests are performed using pressure recording gauges, dead weight

pressure gauges and Type K thermocouples. Dead weight pressure readings and Type K thermocouple readings are recorded every hour and documented on a formal pipeline pressure test report. The pressure recording gauge continuously records the test pressure on a chart and the chart is submitted along with the approved pipeline pressure test report.

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Southwest Gas: SWG uses a chart recorder verified with a dead weight or certified gauge.

Washington Gas: The following instruments shall be used to monitor and measure hydrostatic test data: 1. Deadweight tester capable of accurately measuring in one psig increments. 2. Recording pressure gauge with circular chart graduated in maximum 50 psig

increments. 3. Ambient temperature recorded manually at thirty minute intervals or

continuously with temperature recorder. We do not specify the make or model, just that all instruments have calibration records within the past 12 months. We use a dead weight for hydrostatic pressure tests.

We Energies: A dead weight and pressure recording chart is used for pressure tests greater than an MAOP of 60 psig.

14. For your transmission hydro-tests, do you test to 90% SMYS strength test, and if so, for how long? What is

your maximum %SMYS allowed?

AGL Resources: Typically to 90% SMYS, 8 Hours with detailed plan, max allowed is 100% SMYS

Alabama Gas: Test to 1.5 times MAOP, not based on % SMYS

Citizens Gas: We have been testing at a minimum of 1.5 times the design pressure based on Class 3

but are looking at going to 90%SMYS. The time requirements are based on pipe volume and design pressure; over 30% SMYS and over 2,000 cubic feet 24 hours, under 2,000 cubic feet post installation 8 hours, under 2,000 cubic feet before installation 4 hours, under 30% SMYS 1 hour test.

Consumers: No, we test to 1.5 times the MAOP for a 4 hour minimum (short sections or prefabricated assemblies), but normally 8 hours. Maximum %SMYS allowed is 90%.

Enbridge: 100% SMYS – 4 hours

National Grid: We do not normally test to pressures near 90% SMYS. The reason being that maximum % SMYS is just under 40% for design and more typically under 30%. Hydro tests pressures start at 1.5X the MAOP and may exceed that depending on location, and the future operating pressure that is planned for the line. For example, a 124 psig distribution line may be hydrotested to 525 psig to allow for a future uprate to 350 psig. In this example the % SMYS of the hydro for a 24”, .375 wall, Grade X42 pipe to be operated at 124 psig and eventually uprated to 350 would be 1.5X 350 = 525 psig. This would equate to 40% SMYS.

NJ Natural Gas: We test to 90% SMYS for a 24-hour period, not to exceed 95%.

PECO: Transmission tested to 1.5 MOP PG&E: For pipelines 6” and larger, designed to operate at more than 40% of SMYS,

consideration should be given to test to a minimum of 90% of SMYS, and as close to 100% of SMYS as practical. (Tests of ERW pipe should be limited to a maximum of 95% of SMYS.) Note, we test all new pipelines designed to operate above 40% SMYS to a minimum of 90%. The duration of the test is done to DOT requirements: 8 hours for pipelines operating over 30% SMYS; and 1 hour for pipelines operation below 30% SMYS.

Philadelphia Gas: 100% SMYS Spike test for 1 hour for Shielded Stress Corrosion Cracking.

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Puget: The maximum % SMYS allowed during transmission hydro-testing strength tests is 50%. The hydro-test must be performed for a minimum of 24 hours unless otherwise indicated in a written procedure. Under no circumstances shall the written procedure specify a test duration of less than 8 hours. If 50% SMYS needs to be exceeded during the hydro-test, then specific requirements and approvals must first be obtained from the Standards department.

Southwest Gas: We will test to 90% of SMYS if it is technically and economically feasible. We test for at least 8 hours for pipeline installations (assemblies or other short lengths will be 4-hour tests). We allow up to but less than 100% of SMYS; there is typically some amount below 100% that is set as the maximum test pressure. As an example, it could be specified to not approach within 50 psig of a point that would be 100% of SMYS.

Washington Gas: We sometimes test to 90% SMYS. Normally we require an 8 hours test. The maximum

allowed is 90% SMYS. We have pressures in the 2500 psi range at a company underground storage facility. This is a Class 1 location operating at a maximum of 72% SMYS, tested to 1.25 MAOP or 90% of SMYS for a minimum of eight hours.

We Energies: It is Company standard to test to 90% SMYS if the pipe is 6” in diameter or larger installed in class 1, 2, or 3 location and to be operated over 30% SMYS. All steel pipelines operating at 30% or more of SMYS is to have a minimum test duration of 8 hours. We try to keep our steel high pressure pipelines under 20% SMYS if possible.

15. What transmission pipeline ball valve products are available? What steel distribution plug valve products are

available?

AGL Resources: N/A

Alabama Gas: Trunion Mounted Ball Valves ( Cameron) for high pressure and larger diameter conditions. Various brands of plug valves used (Kerotest)

Citizens Gas: Transmission - Becker, Grove. Distribution - Nordstrom Rockwell.

Enbridge: Ball valves are preferred for transmission pipelines. We install gate and ball(PE) valves in our distribution system.

National Grid: National Grid uses Delta, Grove, and Cameron trunnion mounted transmission ball

valves. Steel and iron distribution plug valves are Nordstrom.

NJ Natural Gas: We currently are using Cameron/Grove and PBV ball valves on transmission, and Nordstom and Walworth plug valves on distribution. Looking for proven alternatives.

PECO: There are a number of suppliers for transmission ball valve products REDQ (formerly Grove), Cameron, and Kerotest – are a few that come to mind. For distribution plug valves, Flowserve Nordstrom and Cameron.

PG&E: Gas transmission ball valves manufactured by Grove, Cameron, PBV-USA, Valvitalia

(Delta), and KF. Steel distribution plug valves manufactured by Nordstrom (Flowserve), Walworth, and Serck Audco. PG&E also uses steel gate valves (Kerotest EV-11 and Kerotest M-1) and steel ball valves (Kerotest Weldball and Broen Ballomax) in its gas distribution system.

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Philadelphia Gas: Cameron and PBV trunnion mounted ball valves. We do not use plug valves. Puget: PSE primarily uses Cameron trunnion-mounted ball valves for transmission and

distribution pipeline ball valve applications. Nordstrom Dynamic Balance steel plug valves are primarily used for distribution pipeline plug valve applications.

Southwest Gas: SWG has approved the use of Broen/Ballomax, Grove, Kerotest Weld Ball, Delta, and WKM/Cameron valves ball valves. We have Nordstrom approved for plug valves.

Washington Gas: We normally use Cameron or Grove Ball Valves. We normally use Rockwell Plug Valves.

We purchase ball valves from Cameron, Grove and PBV companies. We have reviewed their products and determine that each has large diameter valves that meet our specifications. When selecting valves from the three companies, price and lead time are the two main ordering criteria during the selection process. Our distribution gate valves are currently supplied by Kerotest Manufacturing.

We Energies: We typically use Delta, Grove, or Cameron ball valves for transmission pipelines. We

may use Nordstrom/Rockwell plug valves for steel distribution but may use gate as well as ball valves for distribution pipelines.

16. Is your construction inspection data collected electronically? If so, in what software/format? On what kind of

device (laptop, handheld)?

AGL Resources: Yes, through a hand held PDA and an in-house Contractor Quality Assurance (CQA) database

Alabama Gas: Data is collected manually.

Citizens Gas: No, paper field notes.

Consumers: No, construction inspection data is not collected electronically.

Enbridge: QC data is captured manually and then inputted into software in office. Main As-built information is captured manually on a “D” size sheet and scanned for viewing electronically through iViewer and eGIS Service records are manually captured on Job Cards and are scanned for viewing electronically through iViewer and PMTS. Data is also entered through eField or STORMS and migrated into PMTS

National Grid: Construction data is not collected electronically.

NJ Natural Gas: We are currently collecting inspection data on a paper form, and have just recently developed a MS Access form/database.

PECO: No PG&E: Some. Approximately 80% of our construction inspection records are recorded in hard-

copy paper records. The remaining 20% of our inspection records are recorded electronically through email, word or excel.

Philadelphia Gas: Not yet but construction inspection data will soon be captured via an in-house

developed software called AIMS, Advanced Intelligent Mobile System. Data is captured by field forces on laptops.

Puget: No.

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Southwest Gas: Electronically as well as hard copy for various functions. Laptop is used, as well as ruggedized laptops called “Go Books”

Washington Gas: No

We do not currently collect inspection data electronically.

We Energies: No, our construction inspection data is not collected electronically. It is manually collected in the field on paper and then transferred to an electronic application.

NiSource – Christine Maynard

17. Are your company's Engineering and Construction teams under one management group, or are they under two distinct management departments?

AGL Resources: One management group

Alabama Gas: In process of organizing company around three primary areas – New Growth, System Integrity (repair/replace) and Customer Service. Engineering function will be in the System Integrity area and there will be construction teams in both New Growth and System Integrity

Citizens Gas: All under one group.

Consumers: They are under two distinct departments.

Enbridge: With the last reorganization Engineering was moved under Operations. Operations includes Construction, Maintenance and the Work Management Center

National Grid: Currently there are two separate departments reporting to different Senior VP’s

NJ Natural Gas: Ours is under one area – Engineering, Drafting, Construction inspection, Contractor coordination (scheduling).

PECO: Ultimately, they both report to one vice president, but our central engineering functions report directly, where construction and maintenance report to a director. There are regional engineers within that group also.

PG&E: Engineering and Construction are under separate Management Departments.

Philadelphia Gas: Separate business units with separate managers. At the top of the hierarchy is VP

Operations.

Puget: PSE employs a Service Provider model for all construction activities and does not have an internal construction team. Therefore, the Engineering and Construction teams fall under different management departments as well as under separate companies.

Southwest Gas: Each Engineering group and Construction group reports to its own separate Manager.

Those Managers report to a single Director for each operating region.

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Washington Gas: Engineering and Construction report up to the same Vice President. There are project engineers/managers for work that Corporate Engineering initiates who are responsible for holding pre-bid, bid evaluation, pre-construction, and status meetings which include project managers/construction supervisors/contractors overseen by construction as appropriate depending on the phase of the project. The intention is that the engineering/design is not disconnected from the execution of the work – it’s not flipped over the fence with no responsibility past the planning. The routine new business and replacement work is done outside of the Corporate Engineering but under the same Unit Head. Corporate Engineering handles all transmission and large-diameter pipeline & related work and all design and project management related to plants, gates, and storage facilities.

We Energies: They are under two distinct management departments.

18. What are your company's guiding policies or practices for determining maximum spacing of emergency valves for sectionalization/isolation areas? (i.e., gate stations, xxxx number of customers, potential amount of time

for each customer to be without gas service when affected by an outage)

AGL Resources: For transmission pipelines, sectionalizing valves are spaced in accordance with 49 CFR Part 192.179. For distribution systems, company practice is to limit isolation areas to 10,000 customers or less.

Alabama Gas: Depends on site and length of pipeline. Have seen about 5 miles b/t valves on long HP

mains, closer if mains are shorter in length. Sectionalization valve installed downstream of every district regulator where is anticipated that more than 1 feed will tie-in to the system the regulator is feeding.

Citizens Gas: Transmission is based on Class 3 requirements and Distribution are at major

intersections, we serve Indianapolis only so we don’t have long runs out to rural towns or isolated areas.

Consumers: We follow the Michigan Gas and Safety Code based on class, location, etc.

Enbridge: Install valves to maintain isolation areas of 2500 customers or less.

National Grid: Typically the valve spacing is determined by Federal and State codes. Sectionalizing districts are established for approximately 1,250 customers. The valves to isolate the sectionalizing districts are included in the valve inspection program. If there is a need to shutdown an area you would try to isolate as small an area as possible and go to the larger sectionalizing district only if required.

NJ Natural Gas: We use geography as the primary basis for our distribution sectionalization areas (such

as highways, railroads, bridges, etc.), and attempt to use regulator station valves first. Next we consider main diameter. Number of customers, while a consideration, has no set number limit at this time. We view these areas for use in extremely catastrophic events only, thus they are relatively large scale.

PECO: Generally, major lines have emergency valves spaced every 1 to 2 miles. Beyond that, emergency valves are installed to keep the number of customers impacted to 500 or less.

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PG&E: Distribution Based on class-type, maximum number of customers per zone, and physical boundaries: Zones shall not be greater than 500 services in all locations having buildings that are predominantly four stories or higher and/or are wall-to-wall paved in major, metropolitan downtown business and commercial areas. In all other locations, zones shall not be greater than 40,000 services. In localized areas that have an extreme likelihood or history of natural disasters (e.g., faults, landslides, liquefaction, wildfire potential, etc.), additional zones may be established. Natural physical boundaries, such as rivers, mountains, and highways, shall be taken into account when establishing zone boundaries.

Philadelphia Gas: We design for 18 different failure plans. Each plan is based on number of affected customers and piping configurations and how they influence the system. On a smaller scale we typically design our system where no more than one regulator station is isolated at one time.

Puget: The spacing and installation of emergency valves for sectionalization/isolation will vary depending on pipeline operating pressures, local population densities, emergency section boundaries and potential pipeline threats. High pressure block valve intervals should not exceed distances of 1 mile and shall not exceed distances of 2 miles in populated areas. In sparsely populated areas, HP block valve intervals shall not exceed 5 miles. Regardless of spacing, HP block valves should also be installed between district regulator stations and on all branches off of HP mains or transmission lines. Intermediate and low pressure block valve installation locations and frequencies are dependent upon nearby population densities, main/branch sizes, main locations, branch tie-in methods, one or two-way feeds, number of existing and potential customers and emergency section characteristics. Regardless of operating pressure, block valves shall always be installed in close proximity to both sides of a bridge and/or water crossing installation.

Southwest Gas: SWG isolation areas are broken into groups of approximately 5000 customers where practical or less in the distribution system. Valves on the high pressure distribution and transmission systems are space per code requirements at a minimum, with additional valves installed based on emergency response time or to add the ability to re-route service. Each regulator/gate station will include inlet/outlet valves that can be used as part of our isolation plan for distribution or transmission.

Washington Gas: These isolation areas are referred to internally as “safety sectors” and are delineated to

limit each sector to a maximum of approximately 800 customers with control of any sector achieved using not more than eight valves.

We Energies: We usually target a maximum number of customers isolated within an Emergency Valve

Area of 500 customers. In rural areas, we may target less due to the possibility of increased response and relight times. We also take into consideration whether or not the valve is located on a header main, near a station, etc. We also have smaller isolation areas within Emergency Valve Areas called Smallest Isolatable Areas which are isolated using convenient valves (inspected once every 5 years) or a combination of emergency valves and convenience valves and can reduce the number of service interruptions if necessary.

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19. Do you use any kind of component tracking system for materials installed in the field? (e.g., barcode

scanning linked to GIS)

AGL Resources: No

Alabama Gas: No

Citizens Gas: Not yet.

Consumers: No.

Enbridge: No

National Grid: We are in the midst of evaluating different types of barcodes and scanning devices to track & trace material. We do not have capability to link it with GIS at the moment.

NJ Natural Gas: Materials are tracked in our work management system based on the type of material

issued to a project, but it is not item specific, i.e. to a serial number level. We are currently investigated a bar code system, with a possible GIS link.

PECO: No. PG&E: No. We manually track serial numbers, heat numbers, installation locations, Purchase

Order information, etc. on components that retain pressure (pipe, fittings, mechanical couplings, pressure/temp transmitters). We are utilizing SAP to track the up front data (Purchase Order data, heat numbers, serial numbers, etc.) and upon material delivery to the field, the data is tracked electronically and on paper.

Philadelphia Gas: No

Puget: No.

Southwest Gas: We manually enter data into our GIS for a limited number of components including pipe and valves. We are working with Hitesh Patadi on the material tracking initiative he is heading up to this topic. We plan to assist him in testing some of the materials provided by vendors with a bar code that correlates to the 16 digit number assigned by the new ASTM standard for Tracking and Traceability.

Washington Gas: From a Procurement standpoint, no, we do not utilize any type of tracking system. Everything is manual, and other that keeping MTR’s, we do not even track materials received or issued by lot or batch. As part of the Integrated Supply initiative, we are working with Matt Esmacher to identify a list of 100 items that Ferguson Enterprise, Inc, (FEI) would be able to provide some level of batch/lot tracking during the initial go live. The use of bar code scanning linked to GIS would not be included in the first phase, but could be evaluated after go live as part of an additional project, should WG wish to go that route. FEI is able to support full material tracking capability up to the point that they give the material to a WG employee or WG contractor, but after that, it would be on WG to track all the way to ultimate installation location.

We Energies: No.

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20. Have you been successful in obtaining blanket permits for construction activity, annually or geographically, from municipalities or state DOT? If so, please explain.

AGL Resources: In GA, the company has replaced over 2500 miles of cast iron and bare steel pipe over

the last 13 years where much coordination has been made with obtaining permits. This has been performed by educating those involved on our replacement program as well as maintaining good relationships with those providing the permits.

Alabama Gas: Not attempted. Permits submitted on a per job basis (where required)

Citizens Gas: No.

Consumers: Yes, we have been successful with DOT, counties and municipalities.

Enbridge: No

National Grid: For main installation or replacement projects, we have to apply for individual permits. However, we have been successful at negotiating blanket permits for our proactive service replacement program. Since it’s a PSC mandated program based on our rate case and it’s in the customers’ best interest from a safety perspective, many of our local municipalities have waived the permit fees and issued the company a blanket permit.

NJ Natural Gas: We have been successful in setting up blanket permits in some municipalities and

counties, but not a majority. These are for single openings only, typically for service taps, CP work and leak repairs. Trenches must still be permitted separately.

PECO: No. PG&E: Yes, we have obtained blanket permits for performing some types of maintenance work

within Caltrans ROW. These are renewed on an annual basis. We also have Franchise Agreements with various cities and counties within our service territory. These Agreements allow PG&E to perform work on our facilities by obtaining Encroachment Permits, which are ministerial actions.

Philadelphia Gas: No

Puget: With the exception of one particular county in PSE’s service territory, blanket construction permits for “major” projects cannot be obtained anymore. The county that does still issue blanket permits for major work will only do so in situations where there is already an existing road improvement project. However, PSE would still need to submit a traffic control plan to the county for review and approval before proceeding with the job. If the scope of work is such that it can be defined as a “minor” project, then most jurisdictions will still issue blanket permits. Again, many blanket permits would still require a traffic control plan and/or a pre-inspection notification.

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Southwest Gas: SWG has been successful in obtaining a Blanket Maintenance permit from the Arizona Department of Transportation (ADOT) Tucson District that is renewed on an annual basis. This was something developed from a 2002 partnering workshop between SWG and ADOT. There may be one or two other ADOT district offices in Southern Arizona who issue blanket maintenance permits, but not all the ADOT districts have embraced this concept. If you need any additional information relating to the details of this blanket permit, feel free to contact Jody Settles at [email protected]. SWG has also been fairly successful in obtaining blanket construction permits from a handful of northern Nevada entities - El Dorado County DOT, City of Fernley and the Town of Truckee. Each of these entities sends us an annual renewal notification. For additional information on these permits, contact Christopher Anderson at [email protected].

We Energies: Yes, blanket state permits have been obtained for wetlands and on occasion local

blanket permits for broad/repetitive work such as many street openings in a localized area.

21. Do you charge customers for delivering elevated pressure (above 14" w.c.) to their meter? If so, based on

what operational criteria and what pressures?

AGL Resources: No

Alabama Gas: No. We serve several residences with 2# deliveries. Commercial/industrials based on need and availability of higher pressures. If system improvements are required, then charges may apply.

Citizens Gas: No.

Consumers: We charge for anything above 7”. If the customer gets elevated pressure we have a one-time charge.

Enbridge: For PSI delivery we charge customers for the cost of the station.

National Grid: We typically do not charge for elevated pressure.

NJ Natural Gas: No, we do not charge for elevated pressure. We provide 8” w.c. & 2 psig to new customers as a standard. Anything over that is on a case by case basis, along with caveats that full pressure may not be available during peak demand times.

PECO: No PG&E: No, There is no service charge for elevated pressure if the existing gas system’s

prevailing pressure is above standard delivery pressure of 6” w.c. However, if a customer requests a higher pressure than is available from the gas system for its existing or added, or new load, the customer is required to pay for the incremental facilities required to supply the elevated pressure (Special Facilities).

Philadelphia Gas: All sets with a delivery pressure greater than 14” w.c. are welded. The labor component

is included in the total cost and is part of the Allocation of Customer Contribution.

Puget: PSE does not specifically charge customers more money for an elevated pressure delivery beyond 6” water column. However, additional meter set and customer equipment requirements will typically drive up the customer’s cost to install or modify their service.

Southwest Gas: No.

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Washington Gas: Washington Gas follows its jurisdictional tariffs which require us to include all costs

involved in installing gas infrastructure in order to provide service to a customer into the tariff-prescribed contribution calculation. A customer payment would only be required if the revenues were insufficient to recover all the costs involved in providing service, the facilities required to provide increased pressure being just one of those costs.

We Energies: If the elevated pressure is available on the system without causing a system constraint and no system improvements are required, the customer would receive the elevated pressure at no cost. If system improvements are required to deliver the requested elevated pressure, that cost would be included in their total project cost which determines the customer’s contribution.

22. Has it been your company's experience that delivering elevated pressure to customers increases system improvement thresholds, which thereby increases capital spend to maintain commitments?

AGL Resources: In the company’s largest service area the company has replaced over 2500 miles of cast iron and bare steel pipe over the last 13 years where pressure improvements have been made as well during these upgrades. For this reason the company has not experience these concerns for the most part. However, the company has implemented a new program to provide additional feed where excessive growth has been experienced in outlying areas.

Alabama Gas: Use system modeling to determine if it is feasible to offer higher delivery both now and in the future. As additional load increases, then improvements, as necessary, have been made to meet customer needs.

Citizens Gas: No.

Consumers: Typically no, however in certain circumstances in which we have agreed to a high pressure distribution delivery point we have experienced this.

Enbridge: Yes

National Grid: No.

NJ Natural Gas: No, we have not yet found this to be the case.

PECO: No, available delivery pressures are well below minimum system pressures. All large (over 1 MCFH) load requests for elevated delivery pressure must be approved by central engineering.

PG&E: See answer 21. While incremental facility improvement (Special Facilities) costs are

paid for by the customer, the elevated pressures are not guaranteed and the available pressure can be reduced over time. Therefore there has not been increased capital spending to maintain commitments.

Philadelphia Gas: Yes. We take into account elevated delivery pressures when sizing mains and services.

Puget: This has not historically been PSE’s experience delivering elevated pressure to customers, but there is the potential for this in the future.

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Southwest Gas: Yes, increasing delivery pressure will require more robust systems; we generally design for a minimum of 12 psig at the main to prevent any low-pressure issues because of that. We have a formal process for approving elevated pressure meters. Systems with operating pressures both normal and during peak loads that do not support requested delivery pressures are not approved without system improvements.

Washington Gas: The minimum design pressures for our distribution systems are at a low enough

threshold that we are not frequently having to make system improvements in order to maintain them.

We Energies: It has not been our experience yet.

23. Does your particular state have any type of regulations that require cast iron pipe to be removed? If so,

under what circumstances?

AGL Resources: Yes, in GA, the company recently completed its 12 year cast iron replacement program where all cast iron pipe has been replaced. Under the program the company benefited from a rider that guaranteed recovery where penalties were also in place based on set yearly performance measures. The company is also seeking similar type recovery programs in other states we operate.

Alabama Gas: No - although our state Public Service Commission has required some individual

Municipal Gas Systems to replace their cast iron based on their operational record

Citizens Gas: Not that I’m aware of.

Consumers: No.

Enbridge: No

National Grid: Not Yet

NJ Natural Gas: No, we do not.

PECO: No PG&E: No. Philadelphia Gas: No, there are consent orders with individual companies that require a minimum amount

CI removal annually. Puget: There is no state imposed regulation governing the removal of cast iron pipe in the

state of Washington. However, PSE implemented its own cast iron replacement program as part of a settlement agreement with the state. The program has since been completed and there is no longer any cast iron pipe remaining in PSE’s gas system.

Southwest Gas: N/A; no cast iron in our system. We Energies: No cast iron pipe exists in our systems or state.

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24. Does your company have a formal internal training department or program to help train new engineers

and/or provide refresher training to those engineers who are more experienced? If so, what are the types of

training you provide internally?

AGL Resources: The company currently performs internal audits of its operations in accordance with regulatory requirements where new engineers perform these audits under the guidance of more experienced engineers.

Alabama Gas: Engineers are trained within their department but not in a formal manner.

Citizens Gas: Define Engineer and the functions they perform.

Consumers: No.

Enbridge: We have an Engineering Professional Development Program for new engineers. Program includes job rotations to gain understanding of various aspects of business. For technical engineering training, we bring in experts to train, send engineers to training courses(corrosion prevention training, CSA Z662 code training, GTI engineering/planning course, etc.), and make use of job shadowing.

National Grid: A formal training program has recently been developed but not fully implemented. Training is provided by in-house subject matter experts and by external personnel and schools. Internal training on regulator sizing, heater selection, metering, and directional drilling are available as well as pipeline pigging.

NJ Natural Gas: We do not have a formal training program for engineers. While we do send them to

some of the commercially available training, most training is done “on the job” with an assigned mentor. They do get internal training on certain topics such as environmental concerns or leak survey as background, similar to our field forces.

PECO: No formal program PG&E: No. New engineers learn by OJT, Company sponsored training M&C Schools, off-site

vendor training and mentoring.

Philadelphia Gas: Yes, a Field Operations focused 20 week training program.

Puget: For entry-level engineers, PSE has established an Engineer-In-Training (EIT) program that lasts between 12-15 months and rotates the engineer through numerous technical and non-technical work groups. In addition to learning about the gas system, the individual obtains an overall understanding of how company departments function and interact with each. After finishing their rotation, the individual will work with the program coordinator and department supervisors for placement into a full-time position. Once permanent full-time positions have been established, training for engineers happens primarily on a department by department basis and is generally informal in nature. Training can consist of presentations,conferences, one on one mentoring, attending vendor courses, roundtable discussions, and field visits with Operations and/or construction crews.

Southwest Gas: We have recently (last couple years) created a 3-day course that covers the basics of engineering design within our operations manual. It addresses basic design topics like testing, material selection, and special requirements like those needed for bridge crossings. Our intention is to only have this class for new engineers, but we are requiring our more experienced engineers to attend at first to create a ‘base knowledge level’. Currently this effort is primarily contracted.

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Washington Gas: We are utilizing the training modules developed by WG for operations and construction groups. We are currently working on training modules specifically for new engineers.

We Energies: No, each new engineer is provided mentoring from experienced engineers on an individual basis.

PG&E – Todd Hogenson

25. In light of the August 11, 2010, PHMSA interpretation 192.619, how are LDCs considering how they may

establish MAOPs of their pre-1970 distribution systems where there are no pressure records available from the July 1, 1965 - July 1, 1970 period? For reference, see the attached PHMSA interpretation dated 8/11/10.

AGL Resources: For these areas, the company has actively used the affidavit approach in the past. Based on the interpretation, the company is still evaluating its approach to bring these areas into compliance as per the interpretation.

Alabama Gas: Currently reviewing

Citizens Gas: We have pressure records.

Enbridge: 192.619 is not applicable in Canada. However we will be looking at this for due diligence purposes.

National Grid: National Grid will require Hydro records for the establishment of MAOP for those line segments without records or a new Hydro will be performed.

NJ Natural Gas: We fortunately have pressure test records for all our active transmission pipelines.

PECO: Still investigating

PG&E: We are considering developing a process, which will consist of performing an uprate for those pre-1970 systems for which we have no pressure records from the 1965-70 period.

Philadelphia Gas: We are reviewing.

Puget: All PSE pipelines were designed and tested in accordance with ASA B31.8 prior to 49 CFR 192 establishment, therefore MAOP for pipelines that were installed between 7/1/65 and 7/1/70 were mostly likely established based on 192.619(a)(1) or (a)(2) at the time when 49 CFR 192 became effective. MAOP for pipelines that were installed before 7/1/65 were established based on 192.619(a)(3) or (c) at the time when 49 CFR 192 became effective. When a pipeline segment pressure record can not be found during an uprate system review per 49 CFR 192 Subpart K, that pipeline segment will be pressure tested to support the intended MAOP.

Southwest Gas: The attached interpretation referred to pipelines installed before July 1, 1970 that are without pressure tests or OPERATING RECORDS. SWG has operating records and/or test records for most of our systems that were installed before July 1, 1970. For systems without test records, we use the operating records (including pressure charts) to establish a historical operating pressure which will be used as the MAOP. For some acquired systems we worked with the state regulators to designate an alternate operating window to establish MAOP based on operating pressures.

Washington Gas: We are considering requalifying segments that do not have a pressure test report.

We Energies: We are currently conducting a detailed review of our pressure test records. No decisions have been made at this time as to what we will do if we have missing records.

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26. What is your company's operational experience and observations with the Heath DP-IR, Infrared gas leak

detector instrument?

AGL Resources: We do not have any direct experience with this product, however, our leak survey contractor has been slowly incorporating these type detectors into their survey process where the company has not experienced any adverse issues with their use at this time.

Alabama Gas: Tested it on a trial basis along with other leak detectors. No purchases made, but the

evaluation yielded positive feedback.

Citizens Gas: Works great for hard to access areas in leak survey

Consumers: None – do not use

Enbridge: We do not use the Heath DP-IR

National Grid: National Grid has not used the Heath DP_IR. Check with SoCal Gas they are using it

NJ Natural Gas: We use it and have been very happy with its operation. It is a compact, contained, lighter-weight unit requiring no fuel to operate.

PECO: We haven’t used this instrument. PG&E: We are looking at the DPIR (Detecto Pak – Infrared) as a promising new tool to replace

some of our aging leak survey instruments. We have received feedback from three other utilities and are looking to get feedback from more utilities. We anticipate making the go/no go decision soon.

Philadelphia Gas: PGW does not use this instrument.

Puget: PSE does not use the Heath DP-IR leak survey instrument.

Southwest Gas: We do not utilize this piece of equipment

Washington Gas: The RMLD is the direction we are going in for leak survey and is made by Heath also. It can also be used as a mobile device but requires a sample like the older units. The OMD is also made by Heath and we prefer it for that application. Comparison should be limited to the Rover. The Rover uses catalytic technology for methane detection. It does however offer different sensors for CO and oxygen. It also now has GPS capability too..

We Energies: We are currently evaluating the Heath DP-IR unit and determining the appropriate use for the unit at our company. We have noticed that it appears to be missing minor leaks that may be on the back side of piping or gas facility.

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27. Does your company have a written new product approval process? Does this process include a step to check on whether the product is being used successfully in the field shortly after it is introduced for company-wide

use? Please provide name and contact information for this process.

AGL Resources: Yes, no.

Alabama Gas: In process of formalizing a new product approval process. Currently, corporate engineering group is responsible for that function.

Citizens Gas: Yes, test and evaluation process, product is tested by field personnel. if it’s accepted it is put into stock. Dan McBride (317) 927-6018.

Consumers: Yes, we have a written new product approval process, called the material specification process. No, it does not include a step to check. Contact: Matt Beach, [email protected], (517)788-5855

Enbridge: Yes. Yes. Contact: [email protected]

National Grid: We perform our own in-house testing and approval of new products. Our testing protocol includes field operations oriented tests. We have a process in place to report the non-conforming material.

NJ Natural Gas: New products are evaluated by an internal cross-functional committee for value, function, etc., and if considered worthwhile, are tested for a determined period of time in the field. We will also contact other current LDC users of the product to determine their operational observations/experiences. Post-testing evaluation is reviewed, and the product is approved, deferred or rejected for use at that time.

PECO: Yes and the process includes a pilot period before it is accepted. Mark Andraka runs

this process – see Mike Lyons for contact information. PG&E: Yes. We do not currently have a formalized in-field quality control inspection step to

check on the use of the product by the workforce shortly after introduction. We are currently reviewing the need for this step to ensure that the entire workforce can successfully use the new product.

Philadelphia Gas: Yes. It focuses on worker safety as it relates to chemical content of the product and the

employee right to know law. The field evaluation procedure is not written. Manager Chemical Service, Hung Chau [email protected] and Training and Operator Qualification Manager, Beverly Bright [email protected] are your contacts.

Puget: PSE has a written approval process for new products, but it does not include a follow-up step for reviewing the success of the product in the field. After the testing and approval phases have been completed, further feedback about the product is typically initiated by field personnel.

Southwest Gas: Yes; Gas Operations Support Staff will procure the equipment for field trial. Once it has been put through the trials in the field they will determine if it will be approved or disapproved for purchase; Sheila Crump ([email protected])

Washington Gas: We have a Standards & Materials committee that reviews and approves all materials.

Contact Person: Bebe Kaba (Material Engineer) (703)408-3844

We Energies: No, we currently do not have a formal written new product approval or review process.

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Philadelphia Gas Works – Michael Jones

28. Does your company make use of 12” plastic in distribution systems? Are you willing to share your operational experience and observations with 12” plastic with us?

AGL Resources: The company currently operates approximately 3.5 miles of 12-inch medium density PE pipe operating at 60 psig. We can share as much operational experience and observations as available.

Alabama Gas: Not commonly used but have used on rare occasions

Citizens Gas: Yes, yes Jeff Montgomery (317) 927-4672.

Consumers: No.

Enbridge: Yes. Yes. Contact: [email protected]

National Grid: We have been using 12” plastic for last 10 years successfully. We can share with you our operational experience and observation. Please contact Perry Sheth @ 516-545-3844

NJ Natural Gas: We used 12” HDPE SDR9 for one project back in the early 1990’s, that was done in partnership with its primary customer (asphalt plant). We do not intend to use it again at this time. Aside from the benefit of the lack of corrosion concerns as with steel, we generally found it to be difficult to fuse, and the loss of capacity unacceptable.

PECO: No – stop at 8” in medium density, 6” in high density plastic. PG&E: No. 8’ is the largest diameter plastic distribution pipe we use. Puget: PSE does not install any plastic pipelines larger than 8” in diameter. Southwest Gas: SWG does not use 12” plastic in our gas systems. Washington Gas: Yes, we have used 12” MDPE and HDPE pipe for many years. We are willing to share

operational experience, etc.

We Energies: We currently do not use 12” plastic in our distribution systems. The largest standard

plastic size for use in our distribution systems is 8”.

29. Do companies allow welding against control fittings, stopper fittings and valves during tie-ins? If so:

AGL Resources: Company practice has been not to weld against a stopper fitting but it has been performed on occasion. In our other LDC’s we have acquired, welding against a stopper fitting is more common. However, we do weld against a valve.

Alabama Gas: Not sure I understand the question fully, but do not think it is something we do in the

form the question was asked.

Citizens Gas: Yes

Consumers: No. Enbridge: Yes

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National Grid: Yes provided a second barrier can be installed such as a bag . The space between the primary seal and the bag is vented and has a trickle purge of nitrogen.

NJ Natural Gas: Yes

PECO: Generally speaking, we don’t weld against these fittings. However, there have been cases where it could not be avoided, and a detailed plan was worked out to have nitrogen purging going continuously during the welding process.

PG&E: No. Welding against control fittings, stopper fittings and valves during tie-ins is not

allowed.

Puget: Yes.

Southwest Gas: Yes

Washington Gas: Yes

We Energies: Yes.

a. What pipeline pressures do you weld against?

AGL Resources: The company arc welds against all pipeline pressures we operate, however, we do restrict oxy-acetylene welding to less than 60 psig.

Alabama Gas: We have welders that would weld on any steel main including those with the highest MAOP’s which for us is 720#

Citizens Gas: 30 psig

Consumers: This varies by situation but generally: For distribution, we can work live up to 60 psi. For transmission, we can work live up to 750 psi.

Enbridge: Up to 500 Psig

National Grid: We are not limited by pipeline pressure

NJ Natural Gas: Distribution only for stoppers, lowering the line to below 125 psig. For valves, up to 700 psig.

PECO: Pressures were not a limiting factor – in the unusual cases where we have welded against a fitting, the pressures were around 60 PSIG

PG&E: N/A

Puget: PSE welds against atmospheric pressure (i.e. 0 psig) during tie-in operations for valves and stopper fittings. Header piping may be live when welding on a stopper, but we are typically not concerned with the header pressure while welding.

Southwest Gas: It is based on % of SMYS, as well as the maximum operating pressure of the tapping and plugging equipment.

Washington Gas: That would depend on the control fitting’s rating, normally below 300 psig.

We Energies: No pressure restrictions.

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b. What other safety precautions are taken when welding against control fittings, valves, et cetera?

AGL Resources: We ensure the valve or stopper is seated properly with no gas seeping by. A ventura will be used to remove any residual gas and in some case nitrogen will be injected into the pipeline being welded. A good practice is to perform welding a safe distance from the stopper fitting and in separate excavated holes.

Citizens Gas: Check for leakage and welder has final say.

Consumers: n/a

Enbridge: Use air mover and nitrogen to dilute bypass gas. Use expanding weld plugs and nipples to block and bleed bypassing gas if welding a cap (plug stays in main)

National Grid: We would provide a fire wall or a separate excavation.

NJ Natural Gas: We do not weld within 9 inches of the stopper. For valves, we open the block/bleed, and use siphons when possible.

PECO: Continuous nitrogen purging. PG&E: N/A

Puget: When welding a tie-in near a linestopper, 18” of separation is provided between the weld and the rubber stopper to avoid heat damage. If there is a potential for the presence of gas during welding, PSE will continuously monitor the space between the weld and the gas source for a combustible mixture.

Southwest Gas: Temperature control to avoid excessive heating, wrapping the fitting with wet rags, venting any blow by above the bellhole to ensure a gaseous free atmosphere.

Washington Gas: First we wait to make sure we have control, then we perform a Hot Work Welding

Review prior to welding.

We Energies: We often will install air movers associated with valves and linestoppers and purge the isolated section of pipe to 100% air.

30. How do companies control stresses on pipelines on bridges? Contraction loops; expansion joints; build pipeline to withstand stresses (buckling and stress analysis)?

AGL Resources: Generally, stresses are reduced on pipelines on bridges through spacers at end-walls, hangers with rubber rollers, in some cases expansion joints, etc.

Alabama Gas: Expansion joints are most common. Rarely install new main on bridges.

Citizens Gas: We don’t put anything on bridges.

Consumers: We build/design to withstand stresses in distribution. We do not have transmission pipeline on bridges. Preference would be to not put pipeline on bridge, but rather to bore.

Enbridge: Our preference is to HDD the crossing and avoid a bridge installation altogether. When we install on bridges we build the pipe and support system to withstand the stresses. When the crossing cannot be designed this way we use expansion joints.

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National Grid: Expansion joints are utilized. They may be Dresser type couplings. Occasionally, loops are installed in the piping but this is not common for road bridges but are more commonly found on plant pipe bridges.

NJ Natural Gas: We use expansion joints.

PECO: Expansion loops or joints. PG&E: For bridge spans over 100’, calculations of the thermal expansion forces and stresses

shall be made. It may be necessary to compensate for thermal expansion by the use of pipe fittings using “U” or “L” pipe bends. For spans less than 100’, consideration should be given to providing expansion bends. In addition, a full structural evaluation is performed by a civil or structural engineer.

Puget: PSE incorporates the use of expansion loops and offsets in order to reduce stresses in

the pipeline and to minimize additional loading on pipe hangers. Depending on the length of the bridge, outside consultants with advanced stress analysis software may be used to model anticipated pipe stresses and to design the expansion loops. PSE also prefers that all tie-in welds be performed at a temperature that is most nearly halfway between the expected high and low temperature extremes.

Southwest Gas: SWG designs the pipeline to withstand stresses (expansion joints or loops are used

where practical or if required by the local jurisdiction). Non-rigid supports to attach the piping to the bridge are standard so the pipe will be able to flex.

Washington Gas: We use both contraction loops or expansion joints to handle design stresses on bridges.

We Energies: We typically avoid installation of exposed piping if at all possible but in the past have used the “build pipeline to withstand stresses (buckling and stress analysis)” method. We have also used expansion joints on a few very long crossings of larger pipe.

31. Is the handling and disposal of water that accumulates in your manholes and vaults regulated by localwater

authority?

AGL Resources: No formal requirements can be readily identified at this time.

Alabama Gas: No

Citizens Gas: No

Consumers: No.

National Grid: No. Discharge of water from manholes are regulated by the NYS Dept. of Environmental Conservation and/or the local public works/highway department. If determined to be contaminated, the water cannot be discharged; it must be disposed of according to local and/or state regulations.

NJ Natural Gas: Not sure.

PECO: Pennsylvania Department of Environmental Protection PG&E: Sometimes, it varies depending on location in our service territory.

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Puget: Yes. Handling and disposal of water in vaults and manholes is regulated by the local jurisdiction. Depending on the location of the vault or manhole, the requirements for handling and disposing of water may vary from one jurisdiction to the next. PSE has established its own set of minimum standards for dewatering manholes and vaults that are commonly acceptable to most local authorities, but additional requirements may still be needed depending on the location and/or any site-specific characteristics.

Southwest Gas: Yes, it is.

Washington Gas: Not specifically. However, all discharges are regulated for sediment control and are not permitted into storm drains.

We Energies: No, crews are required to use filter bags when pumping water out of pits/vaults.

32. Have you any engineering design methods to keep water from entering your manholes and vaults?

AGL Resources: No formal methods are in place but water issues are handled on a case by case basis based on surroundings.

Alabama Gas: Attempt to seal our vault opening points as well as possible

Citizens Gas: No

Consumers: No, however we are working on this currently.

Enbridge: The location of district box regulators is selected with the potential for ground water

taken into consideration. All vaults and manholes have been eliminated.

National Grid: We are using coatings and compounds to seal the space between vault roofs and sides. We are using Enecon products to coat corroded piping. Another product called Viscotaq is currently being utilized to seal pipe sleeves against water intrusion.

NJ Natural Gas: We use a closed bottom pre-cast concrete clamshell-style vault, with sealed aluminum

lids (Accudor or Bilco).

PECO: None that have been totally successful. We do have a waterproofing spray that is applied to the pit, and a plastic cover for the manhole lid, but that reduces the water, rather than eliminate it. We design the internal components assuming they will be underwater.

PG&E: Yes - Mastic sealant required with enclosure assembly for all joints 18” below grade. Structures shall be designed to provide a dry watertight installation. - In areas with a high water table , the outside walls of vaults shall be sealed with a water sealant. It is recommended that no joints be located at the floor level. - Request one piece pre-cast vaults to minimize water intrusion. - Require use of link seals to minimize water intrusion at pipe penetrations.

Puget: PSE has tried installing a geo-membrane material around the outside of a new vault installation. However, water was still able to penetrate through the vault lid and flood the vault. In addition, the geo-membrane makes it difficult for the water that gets into the vault to drain out naturally.

Southwest Gas: No.

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Washington Gas: No. However, Corporate Engineering might be using some special equipment, such as covers, that could prevent water from entering these structures.

We Energies: No, nothing that we can recommend. We attempt to place vaults in areas where we can pitch the earth away from the vault opening. If a Bilco Style hatch is used, a drain system is incorporated within the Bilco door pit covers. For hard surface manhole type installations we have nothing specific that we can recommend..

Puget Sound Energy – Leslie Wright

33. Greasing Gaskets: When installing gaskets between two steel flanges, does your Company’s current

installation require applying any grease, dry lubricant, or adhesive to the gasket? If so, what product(s) are

available and what type of gaskets (phenolic, metallic, non-metallic, neoprene, etc.) are lubricated?

AGL Resources: There is currently no formal process in place to lubricate gaskets unless the manufacturer’s procedures require greasing.

Alabama Gas: Not typically

Citizens Gas: No

Consumers: No.

Enbridge: We do not call for any lubricants or adhesives when installing gaskets in the pipeline system.

National Grid: Our company procedure does not require lubricating gaskets between flanges. Only rubber gaskets and o-rings are lubricated using soapy water ( leak detection fluid) during installation

NJ Natural Gas: We do not apply any product to gaskets.

PECO: Flanged fittings are not used.

PG&E: No.

Philadelphia Gas: None, Flanges are wired brushed clean of any residue and gasket material left from removal of previous gaskets.

Southwest Gas: No

Washington Gas: MFG instructions do not require a lubricant or adhesive

We Energies: No, company standard does not require.

Southwest Gas Corporation – Sheridan Green

34. For safety during Inline Inspections, what planning and procedure steps are companies compiling to "walk-through" their pigging? (SWG/PPC compiles a step-by-step procedure for valve configuration and system ops

during this work.)

AGL Resources: Generally, the company has a meeting with those involved in the process to go over the details of the inspection and address any concerns with the process.

Alabama Gas: Do not currently perform ILI.

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Citizens Gas: We do a written plan that is reviewed by the parties involved in the work.

Consumers: We have a pigging planning procedure that identifies all valve configurations for inspection it is reviewed prior to start of the job.

Enbridge: We compile detailed procedures for every step of an ILI inspection. Included in this are procedures for system operation and a contingency plan if something goes wrong or a pig gets stuck.

National Grid: National Grid uses a detailed operating procedure called an SOP during pigging

operations. All steps are called into our systems operation control room.

NJ Natural Gas: We develop a written transmission line shutdown procedure, including a contingency plan (if say the pig gets stuck), and have an environmental procedure in place for testing and disposal of any material removed.

PECO: Currently, our lines are unpiggable, so we don’t have these procedures.

PG&E: We utilize our Gas Clearance Process which involves writing a detailed step by step procedure covering each task associated with actual pigging operations which include; setting up pipeline pressure and flow conditions for pigging, operating the pipeline during pigging, inserting and removing pigs, pig launching and pig receiving , opening and closing tap valves (as required) and monitoring pressure and flow conditions during pigging as well as returning the pipeline to normal operation. The ILI Program uses a standardized pre-pigging checklist that describes all significant tasks leading up to pigging operations.

Philadelphia Gas: We have not performed an inline inspection at this time.

Puget: PSE does not actively perform inline inspections on pipelines.

Southwest Gas: SWG compiles a step-by-step procedure for valve configuration and system ops during this work.

Washington Gas: Start with O&M procedures and add any necessary steps; pre-pigging meeting at least

one-week prior; then a safety meeting at the jobsite

We Energies: Valving Procedure, Emergency Action Plan, Liquid/Debris Removal Plan, & Communication Plan

35. What procedures do companies have in place for opening/closing/de-pressurizing pig traps? (SWG/PPC has a

checklist for proper performance of this step.)

AGL Resources: The company has developed procedure guides to ensure that opening/closing/de-pressurizing pig traps are performed accordingly.

Alabama Gas: Do not currently perform ILI.

Citizens Gas: Written plan for pigging operations.

Consumers: We have blowdown instructions in the procedure mentioned in 34.

Enbridge: We include detailed pressurization and depressurization and purging. instructions, and the door manufacturers instructions are included in the procedure.

National Grid: These procedures are part of the SOP referenced in question 34. The procedure calls out steps to make sure the trap is depressurized and vented prior to opening the door.

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NJ Natural Gas: We have a checklist as well. Major steps: Maintain flow prior to receiver valve being opened. Close all valves to trap. Open block and bleed on all valves. Install grounding clamps on trap. Blow down trap. Install siphon. Open door on trap. Complete environmental containment as needed. Remove pig.

PECO: Currently, our lines are unpiggable, so we don’t have these procedures. PG&E: A PG&E utilizes our Gas Clearance Process for all operations which affect the flow of gas

or could potentially expose company personnel, contract personnel or the public to energized sources of gas. PG&E creates a detailed step by step clearance covering all aspects of pigging operations including opening, closing and depressurization operations. Additionally, maintenance personnel who are involved in pig trap door operations are trained on the specific door manufacturer’s operating procedures by reviewing the manufacturer’s operating manual and by on-site training on such by maintenance personnel who are experienced with pig trap door operations.

Philadelphia Gas: We currently do not have written procedures for opening/closing/ pig traps on transmission pipelines.

Puget: N/A – see answers to question 34.

Southwest Gas: SWG has a checklist for proper performance of this step.

Washington Gas: We have O&M Procedures for pigging operations (11 steps for loading and running, 8 steps for unloading

We Energies: Procedures are written for each specific launcher/receiver site. The following is the general procedure: Lock out/tag out valves, use equalizer line to blow down to zero pressure, verify zero pressure prior to opening launcher/receiver door.

36. What internal resources (if any) do companies have to review compliance to their own policies and procedures? How frequent are these reviews? (SWG/PPC has Staff Compliance, and these reviews are

typically on an annual basis.)

AGL Resources: Policies and procedures are continuously reviewed and updated as needed through our

compliance and system integrity department where a website is identified as well for all employees to notify this department where changes are needed or requested. Should no changes be required within 49 CFR Part 192.605(a) requirements the O&M manual is documented as being reviewed with no changes made.

Alabama Gas: Typically done on an annual basis in preparation for PSC audits.

Citizens Gas: Annual review of procedures through our Standards area.

Consumers: We have a group which was formed in 2011 and is still in its conceptual phase.

Enbridge: We have our own employees conduct QC(daily) , QA(random-daily) and audits(annually on demand).

National Grid: Internal audit & QA/QC inspectors & assessors. QA/QC inspections & assessments are performed on daily basis randomly. Internal audit performs the process audit annually.

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NJ Natural Gas: We have a small group responsible for tracking and reporting compliance status, and reviewing our standards and procedures. Each responsible area manager updates status monthly. We also have a cross-functional committee that reviews and revises these standards, meeting monthly.

PECO: Internal Auditing conducts reviews – timing based on the activity. PG&E: Internal resources include: 1) supervisor level, 2) QC reviews of ongoing processes, 3)

Compliance reviews in preparation of regulatory audits, 4) QA reviews, and 5) Internal Auditing. These reviews occur as needed, with some occurring as frequently as monthly or annually (e.g., leak survey, field services).

Philadelphia Gas: A Technical Compliance group that is charged with conducting gas safety compliance audits. The audits are infrequent and determined by staff availability and operations need. There is also a Corporate Internal Audit office that upon request will assist by providing outside resources to audit programs.

Puget: PSE has a staff of Quality Assurance and Inspection (QA&I) personnel who are responsible for verifying that construction, operation and maintenance work performed on our system is in compliance with company policies and procedures. This is accomplished by examining work in progress, performing audits, compiling statistical reports, etc. QA&I also produces monthly status reports that list the number of deviations needing to be resolved.

Southwest Gas: SWG has the Staff Compliance group do the review, and these reviews are typically done on an annual basis. SWG also has a requirement for Annual Manual Reviews by company subject matter experts to make sure they are all up-to-date and still working properly.

Washington Gas: Standards are reviewed annually. A Standards Committee meets monthly to review

and revise standards as applicable. The Compliance Group audits crew performance and compliance to the standards.

Feedback generated from the audits assists in the standard review process.

We Energies: Supervisors, training staff, etc. are responsible for performing spot audits whenever possible but no formal internal audit procedure/frequency exists.

37. For any companies that have PVC or ABS plastic pipe in their system, have you had any recent issues with availability of solvent cement? What type/brand are available for each material?

AGL Resources: N/A

Alabama Gas: N/A

Citizens Gas: No PVC or ABS.

Consumers: N/A

Enbridge: No PVC or ABS in our gas distribution system.

National Grid: We do not have PVC or ABS in our system.

NJ Natural Gas: We do not have these materials in our system.

PECO: None of these materials on our system.

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PG&E: N/A

Philadelphia Gas: There is no PVC or ABS in our distribution system

Puget: PSE does not have PVC or ABS plastic pipe in the distribution system.

Southwest Gas: We are having issues with the availability of solvent cement. Most brands now state that they are not to be used on pressurized gas systems. This includes brands that have been used for many years and have experienced no changes in formulation. We are currently using IPS/Weld on brands for both, however they both have the warning information on the labels.

Washington Gas: N/A

We Energies: We utilize mechanical fittings therefore we do not use solvent cement and currently have a replacement program in place to eliminate PVC pipe.

38. What process are companies using in DIMP to capture new threats to their systems?

AGL Resources: Automated systems have been put in place to more accurately capture field data into databases where information is being related back to the company’s GIS system. Through these systems, the company has generated its own risk assessment program to identify risk in accordance with DIMP requirements.

Alabama Gas: Review by compliance group on at least on annual basis. Process under development.

Citizens Gas: Annual review with SME.

Consumers: Changes to the pipe are recorded by GIS and incorporated into DIMP.

Enbridge: We examine failure in and damage to the distribution system and define the cause of the failure by using standardized threat categorization then create a risk profile of the distribution gas carrying assets. A secondary level examination of these threats may lead to trends for specific failures being identified. Word of mouth, observations from other sources and one of a kind incidents can all give rise to concepts that may help identify threats to the distribution system.

National Grid: We have company wide Incident Analysis IA system, all significant incidents are reported through this system and analyzed in our Material testing lab where appropriate. DIMP team reviews that incident analysis and determines if it is a systemic problem and should be included in DIMP plan or not.

NJ Natural Gas: We do not have a specific process spelled out in DIMP to capture new threats. In our

day to day scheduled maintenance activities (leak surveys, atmospheric surveys, etc.) anything out of the ordinary or something that is becoming repetitive is communicated to the field supervisors who will then let the DIMP coordinator know.

PECO: SME’s, leaks, Risk Council. PG&E: New threats to the system are identified through a monthly questionnaire program to

the operating groups that has been specifically developed to identify new and previously undiscovered threats upon the system. Responses are vetted through pre-established threat committees that determine whether the identified issue is adequately addressed in the current risk/threat process. If not adequately addressed, the committee will make recommendations to update the current program to address the identified issue.

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Philadelphia Gas: Surveillance, Data Reviews, Trending

Puget: PSE will be using the combination of a continuing surveillance program, a threat prioritization matrix, pipeline record reviews and exposed pipe condition reports (EPCRs) to capture new threats to the system. New potential threats will be identified by tracking trends in the system and prioritizing surveillance efforts accordingly.

Southwest Gas: We have developed a threat "checklist" that is completed by the operations personnel when they discover a new threat that they do not feel is adequately addressed in the DIMP plan. The threat is then reviewed by Staff and in conjunction with Operations, incorporated into the DIMP plan with mitigation plans.

Washington Gas: Annual updates with SMEs, “Knowledge Capture” forms collected from all employees throughout the year

We Energies: New threats are identified through data captured in company systems, subject matter expert interviews and review of industry information (NTSB recommendations, PHMSA advisories, trade publications, etc.).

39. How are you accounting for known "unknown" threats in the DIMP plan on your distribution system, i.e.,

tsunamis, nuclear plant failure, etc.?

AGL Resources: Risks and threats are associated on a grid basis through our GIS where these threats are weighted in on the risk calculations for that grid and pipe types. These grids are also used to identify and perform required leak surveys as well.

Alabama Gas: Process under development.

Citizens Gas: Part of the annual review to discuss unusual threats.

Consumers: None at this time.

Enbridge: Larger scale risk management activities such as “Acts of God” and system disruption based on electricity supply are managed at a more macroscopic level by EGD’s Business Resumption Plan and Emergency Response activities. If desired, a level of risk could be determined for such events. Events of this type of these may become a contributor to DIMP level threats.

National Grid: DIMP team reviews the industry incidents and does include it in the program if our infrastructure and geography poses a similar threat.

NJ Natural Gas: Guidelines for such ‘unknown’ threats are spelled out in our Emergency Manual. It is difficult to plan for such a disaster, but our manual covers the procedures we will follow in the case of such an event, such as hurricanes and service curtailment.

PECO: If it is a known, unknown threat, that typically means the threat may exist, but you

need to collect more data. For example, we did not collect data on meter set leaks – we know we had them, but that data was not collected, so it is a known unknown threat. We are putting steps in place to start collecting that data. For unknown, unknown threats, we established a risk council to review issues and revise our plan accordingly (Apologies to D. Rumsfeld).

PG&E: Same answer as 38.

Philadelphia Gas: Address as they occur or recognized as a potential threat.

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Puget: Existing emergency response plans for any known “unknown” site-specific or general threats to the system will be incorporated into the DIMP plan as they are currently written. No modifications to these existing response plans are expected.

Southwest Gas: This has not been fully addressed in the DIMP plan other than to use the process for

adding new threats as they occur.

Washington Gas: Nothing specifically stated for known “unknowns”; earthquakes were addressed (this will be updated due to recent events

We Energies: Known "unknown" threats are addressed through general emergency procedures and are included in the potential threats section of our DIMP plan.

Washington Gas – Katie Harkless

40. How are other utilities deterring malicious activities that would cause the overpressure of a system (such as

opening a bypass valve)? The real concern would be on a low pressure system. Since there are not any house regulators, the impact would be huge.

AGL Resources: All bypass valves are locked in the closed position and relief isolation valves are locked in the open position to deter any unauthorized operation.

Alabama Gas: Locks, limiting access to system, limiting access to knowledge of location of system

pipelines and operating pressures. Over-pressure protection. Steadily eliminating low pressure systems

Citizens Gas: Locking by-pass valves and requiring valve keys.

Consumers: We install fencing when possible and all valves are locked in proper control position.

Enbridge: If the District stations are in a boxes they are locked. If there is no box the run valves are locked. Where we have a lot of vandalism, which we have had in certain locations we fence the station and have even put a roof on the compound. The monitor and operator regulators are on separate control lines so you would have to know what you’re doing to disable both and then the relief would start going off at the station. I don’t believe we have any LP stations configured with a bypass valve, they are dual run monitor/operator.

National Grid: Typically all bypass valves are locked and tagged. In addition to the bypass locks all Safety or Monitor regulators have locking inner covers at our LP Stations.

NJ Natural Gas: We have no such measures in place, other than lock-chaining all critical aboveground

valves.

PECO: Bypass valves are buried with a key hood, so they are not generally accessible. PG&E: Vaults with lids are bolted shut and some require special tool to remove. We rely on the

weight of the cover for manhole cover vaults. Above ground locations are secured with perimeter fencing (razor wire if required) and the gate is secured with company keyed locks. Valves within the sites are chained and locked.

Philadelphia Gas: All bypass valves are locked or chained and locked.

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Puget: Any new aboveground regulator station will be installed within a locked fence (large stations) or within a locked cabinet (small to medium sized stations). Beyond that, no further action is taken to deter malicious activity to the station or to any system bypass or section valves.

Southwest Gas: SWG uses valve locks to prevent valve tampering.

We Energies: We do not have any low pressure systems without regulators.

41. For maintenance crews how is productivity measured - are there incentives associated with?

AGL Resources: The company has implemented and automated ‘scorecard’ process through which productivity of maintenance crews are tracked and measured. In some cases, scorecard results are associated with the employees individual performance evaluation.

Alabama Gas: Currently implementing a Resource Management System which will include reports and

dashboard metrics that will help measure/track productivity. Do not offer incentives at present

Citizens Gas: Electronic productivity reports are available to our supervisors on a daily basis, there are no incentives.

Consumers: No incentives at this time.

Enbridge: Productivity reports, task efficiency, tool in hand time in past – meaning time / effort to

complete units of work.

National Grid: Productivity of the crews are measured at local/regional levels, certain task are measured company wide like hours for new service installation, main replacements, etc. No, we do not have any specific incentive programs.

NJ Natural Gas: All field personnel (bargaining unit) have productivity measurements on a work group basis, with each group having different measurements that correlate to their responsibilities. Should these targets be met, then all individuals within the particular work group get an equal incentive paid out annually. Some measures: % emergency calls responded under 60 minutes; Average emergency response time; Average time to repair a main leak; Utility service jobs completed per 8 hr day; % utility appointments made on time; Average time to set a meter; Average time to complete a regulator station inspection; Service renewals completed per day; Customer satisfaction %; preventable motor vehicle accident rate.

PECO: Cost per metrics – no incentives.

PG&E: Through accounting and maintenance software applications, we track units completed

and actual hours reported to measure, track and report per unit productivity (hours per unit). Productivity performance is not tied to incentives for the maintenance crew employees.

Philadelphia Gas: Productivity is measured by quality and quantity of work within an eight hour shift.

There are no incentives associated with maintenance work.

Southwest Gas: Each department measures their own productivity due to the diversity of the areas we serve. There are no incentives utilized.

We Energies: The time it takes for a crew to do a job is compared with the average estimated time to do that same job. Currently, there are no incentives offered.

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42. Do others use Contractors in the leak repair and maintenance activities - if so on what type of work and how

is it scheduled/managed?

AGL Resources: Contractors are generally only used for leak repairs or maintenance type work where excess work is determined to be in need of completion before an out of compliance date is exceeded. Where used, tracking and scheduling is maintained manually on a spreadsheet outside of the company’s normal automated processes since the contractor is not set up with the necessary equipment. This information is then incorporated back into the automated systems as necessary.

Alabama Gas: No for leak repair. We do use contractors for some maintenance activities including leak surveys, station painting, ROW clearing, etc.

Citizens Gas: No, not currently.

Consumers: No.

Enbridge: All below ground leak related maintenance work is performed by our own crews, but we outsource some of the following maintenance work, depending on workload:

Tracer wire repairs Anode Installs Meter Barrier installs Service Relays Service Cut Off at Main

We use contractors fitters for above ground (service) leak repair work, appliance inspections, meter and regulator exchanges, emergency response and other meter work.

National Grid: Company has various operation locations across states, only few locations use contractors for leak repairs. Local yards assign work to the contractors based on in-house resource availability and complexity of the leak repair. Contractor work is monitored by contractor inspection group and scheduling is done by the contractor within the required completion dates.

NJ Natural Gas: We do not use contractors to do these activities, other than providing equipment or

restoration needs.

PECO: No contractors on leak repair, but do have them doing leak survey. They are given areas to complete by a certain date, but the daily scheduling is left to them.

PG&E: Yes – as a limited practice during peak periods, we have utilized contractors to assist

with maintenance work, particularly leak repair where contractors provide excavation services, installation of aboveground leak clamps, and mechanical repair of services and mains. When work is done by contractors PG&E informs the contractor of expected timeframe (any due dates) and monitors the work & validates completion through field inspections.

Philadelphia Gas: No we do not use contractors for leak repair and maintenance activities on the energized gas distribution system.

Puget: Yes. We manage the master leak database, and routinely send a list of known leaks to

the Service Provider that are graded as requiring repair or re-evaluation. Our Service Provider (i.e. contractor) is responsible for managing those leaks and conducting repairs in accordance with time frames and methods established in the Gas Operating Standards. The work is managed by the Service Provider, with their performance enforced through our Contract Management department.

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Southwest Gas: If a contractor is on site when the leak is discovered and once the leak is controlled,

then they can facilitate the repairs. We do not schedule contract crews just for leak repair, this is generally handled by company crews.

We Energies: Yes, we use contractors for both leak repair and maintenance activities such as

main/service leak repairs, meter replacements and maintenance (painting, etc.).