managing csef materials

Managing CSEF Materials

Western Regional Gas Conference

Eric Kirkpatrick, P.E.

August 24, 2010

DIMP Implementation Using the NGA/SGA Plan

Gas Distribution Integrity Management

49 CFR, Part 192, Subpart P

§192.1005 No later than August 2, 2011 a gas distribution operator must develop and implement an integrity management program that includes a written integrity management plan


Develop and fully implement a written IM Plan. Plan Elements inlcude:

• Knowledge• Indentify Threats• Evaluate and Rank Risks• Identify and Implement Measures to Reduce Risks• Measure Performance, Monitor Results, Evaluate Effectiveness • Periodic Evaluation and Improvement• Report Results

NGA and SGA Collaborative

• Northeast Gas Association and Southern Gas Association formed a collaborative to develop a framework document and guidelines for a distribution integrity management plan– 58 companies thus far

• Collectively these 58 companies serve more than 55% of the distribution customers in the U.S.

• Structural Integrity Associates is the principal author • NGA and SGA DIMP Steering Committees and

Member companies participated and provided comments and input during development

Companies who are using the Plan

• National Grid• NiSource• Atmos Energy Corp• AGL Resources• Nicor Gas• ONEOK, Inc.• Southwest Gas Corp.• Ameren• Puget Sound Energy• Dominion East Ohio• Consolidated Edison of New York• We Energies• Piedmont Natural Gas• Questar Gas• Puget Sound Energy• National Fuel• Questar Gas

• NW Natural• Laclede Gas Company• Baltimore Gas & Electric• New Jersey Natural Gas Company• Alabama Gas Corp• SCANA• TECO Peoples Gas• Memphis Gas, Light & Water Division• LG&E Energy, LLC• Avista• NSTAR Gas• South Jersey Gas Company• Rochester Gas & Electric Corp.• New York State Electric & Gas Corp• Yankee Gas Services Company• Unitil

Companies who are using the Plan

• Equitable Gas

• DTE Energy – Michcon

• Southern Connecticut Gas Company

• Connecticut Natural Gas Corp

• Arkansas Western Gas Company

• Entergy New Orleans, Inc.

• Orange & Rockland Utilities, Inc.

• Mobile Gas, a Sempra Company

• Florida Public Utilities Company

• Central Hudson Gas and Electric Corp

• Arkansas Oklahoma Natural Gas Corp

• Roanoke Natural Gas

• New England Gas Company

• City of Richmond, VA

• Vermont Gas Systems, Inc.

• Berkshire Gas Company

• City of Holyoke Gas and Electric Department

• St. Lawrence Gas Company, Inc.

• Corning Natural Gas Corporation

• Westfield Gas and Electric Light Dept

• Norwich Public Utilities

• Wakefield Municipal Gas and Light Dept

• Middleborough Gas and Electric Department

• Maine Natural Gas

• Blackstone Gas Company

Plan Framework & User Guide

PLAN FRAMEWORK DIMP User Guide

Written IM Plan Framework

• A Generic Framework

• High Level & Flexible

• Applicable to both the largest and smallest operators ( 3.4 million to 1,400 customers)

• Operator customizes by populating Appendices material

• Operator may use (or incorporate by reference) existing material and reports

Customization via Appendices

Appendix A – Knowledge of Facilities

Appendix B – Threat Identification

Appendix C – Evaluation & Ranking of Risk

Appendix D – Measures to Address RiskAppendix E – Performance Measures, Monitoring Results, Evaluating Effectiveness

Appendix F – Periodic Evaluation and Improvement

Appendix G – Reporting Results

Appendix H – Cross Reference to Subpart P

DIMP User Guide Discussion and Instructions for customizing each section

Optional Plan Sections

77 Sample Data Tables and Forms

A discussion of over 40 distribution threats

Risk Identification approaches

3 Risk Assessment & Ranking approaches

Mitigation strategies

Baseline and ongoing performance measures

DIMP User Guide

Optional Sections for:

• Company Roles & Responsibilities

• Personnel Qualifications

• Knowledge Capture – Subject Matter Experts

• Program Effectiveness for Damage Prevention

Program, Public Awareness, QA/QC

• Exception Process


Plan Elements inlcude:

• Knowledge• Indentify Threats• Evaluate and Rank Risks• Identify and Implement Measures to Reduce Risks• Measure Performance, Monitor Results, Evaluate Effectiveness • Periodic Evaluation and Improvement• Report Results

§192.1007 (a) Knowledge§192.1007 (a) Knowledge. An operator must demonstrate an understanding of its gas distribution system developed from reasonably available information.

Data

Demonstrated Understanding

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

System-wide County Map B7

Leak

s pe

r Mile

per

Yea

r

Leak Frequency Leaks per Mile per Year

Other

Inappropriate Operation

Equipment Malfunction

Material Failure

Other Outside Force

Excavation Damage

Natural Forces

Corrosion

§192.1007 (b) Sources of Data

§192.1007 (b) … Sources of data may include, but are not limited to, incident and leak history, corrosion control records, continuing surveillance records, patrolling records, maintenance history, and excavation damage experience.

ID Key Data Sources

Record

Record Type –Database,

Electronic Record,Paper Record

Applicable Standard, Policy, or Guideline

Extent of Missing Records

Location of Records

Geographic Information System (GIS) database

Gas Leak Repair Records / Database

Gas Leak Repair Database

DOT/PHMSA Incident Reports

Other Incident Reports

Requests to Locate Gas Facilities

Dig-in Root Cause

Main/Service Condition Reports

§192.1007 (a) Knowledge

§192.1007 (a) (3) Identify additional information needed and provide a plan for gaining that information over time through normal activities conducted on the pipeline (for example, design, construction, operations or maintenance activities).

Identify Data Gaps and Document

Documented Action Plan


§192.1007 (a) (1) Identify the characteristics of the pipeline’s design and operations and the environmental factors that are necessary to assess the applicable threats and risks to its gas distribution pipeline.

§192.1007 (a) (2) Consider the information gained from past design, operations, and maintenance.

Incorporate existing reports by reference.



Operators may also wish to consider:

• System Design by Material, Diameter, Operating Pressure

• Historical Construction and Leak Repair Practices

• Cathodic Protection Design & History

• Key Equipment in Use: Regulators, Mechanical Fittings, etc.

• Leak Repair frequency per mile and trend over time

• Material Failure Report Trends

• Excavation damage trends by root cause

• Reportable Gas Incidents

• Seismic Areas

• Flood Zones

• Landslide prone areas

History of Material Types and Years Installed

Material Type

Mains Services

Current Miles of Main

Years Installed (of remaining)

Number of Services

Years Installed (of remaining)

Cast Iron

Wrought Iron

Bare Steel – with CP

Bare Steel – No CP

Coated Steel – with CP

Coated Steel – no CP

Ductile Iron

Copper

Plastic - PVC

Plastic - ABS

Plastic – Century MDPE 2306

Plastic – Aldyl-A

Plastic – HDPE 3306

Plastic – All Others

Historical Construction Practices

Construction Practice/MethodYear first deployed

Year Ceased

Replacement via insertion of Copper

Replacement via Insertion of Plastic

Replacement via insertion and pipe bursting/splitting

Internal lining / slip-lining

Joint Trench with other utilities

Unguided Bore – soil displacement/Ram

Guided Directional Bore / Drill

Blasting

Plow-in

Leak Repair Frequency Rates


Role of Subject Matter Experts• Documentation• Selection and Qualifications

Demonstrated Understanding

May also wish to involve SMEs in:•Threat Identification•Evaluation & Risk Ranking

§192.1007 (b) Identify Threats

§192.1007 (b) An operator must consider reasonably available information to identify existing and potential threats.

SME Involvement in Threat Identification

Sub-ThreatSME’s to Consider the

following

Threat Applicable? SME –

Yes / NoMaterial or Weld Failure

ABS – Acrylonitrile Butadiene Styrene Is ABS pipe known to exist in the system?

Is there a history of leakage of ABS pipe due to material failure?

CAB – Cellulose Acetate Butyrate Is CAB pipe known to exist in the system?

Is there a history of leakage of CAB pipe due to material failure?

Corrosion Threats

• Cast Iron Graphitization• Ductile Iron• Bare Steel • Copper Pipe/Services• Coated Steel Pipe w/o CP• Damage by Stray Current• Internal Corrosion• Atmospheric Corrosion• Pipe installed in Casing

Natural Forces

• Seismic Activity• Earth Movement /

Landslide• Frost Heave• Tree Root Damage• Floods• Snow / Ice Damage• Other – Wild Fire,

Lightning

Excavation Damage

…… The largest threat

Excavation Damage

• Mis-marked facilities• Late Locates• Incorrect info from one-call center• No Call for Locate• Improper Excavation Procedures• Incorrect Facility Records

• Adequacy of Damage Prevention

Program?

Other Outside Force

• Vehicle Damage• Vandalism• Fire or Explosion• Previous Damage

Material or Weld Failure

• Early generation Plastics: PVC, ABS, CAB, PB• Century Products MDPE 2306• Aldyl-A and HDPE 3306• Delrin Insert Tap Tees• Plexco Service Tee Celcon Caps• PE Fusion Failure• Compression Couplings• Pre-1940 Oxy-Acetylene Girth Welds

Plastic Pipe Alphabet Soup: PVC – Polyvinyl Chloride PE – Polyethylene ABS – Acrylonitrile Butadiene Styrene CAB – Cellulose Acetate Butyrate PB – Polybutylene PP – Polypropylene PA – Polyamide PEX – Cross-linked Polyethylene

Fusion Failures

Mechanical Fittings

Nut-Follower

BoltedOther - Hydraulic

Stab

Equipment Malfunction

• Valves• Service Regulators• Regulator/Control Station

Incorrect Operation

• Human Error / Operating Error• Failure to Follow Authorized Procedures

– Unauthorized Installation or Repair Methods– Service Lines bored thru sewers

Other

• Bell Joint Leakage• Copper Sulfide• Construction over gas mains & services

§192.1007 (b) Identify Threats

§192.1007 (b) An operator must consider reasonably available information to identify existing and

potential threats. Sources of data may include, but are not limited to, incident and leak history, corrosion control records, continuing surveillance records, patrolling records, maintenance history, and excavation damage experience.

Threat Identification –PHMSA Advisory Bulletins

Year

PHMSABulletinNumber Subject Summary

2008

73 FR 12796 -

ADB-08-03

Dangers of Abnormal Snow and Ice Build-up on Gas Distribution Systems

Recent events on natural gas distribution system facilities appear to be related to either the stress of snow and ice or malfunction of pressure control equipment due to ice blockage of pressure control equipment vents by ice. This advisory bulletin advises owners and operators of gas pipelines of the need to take steps to prevent damage to pipeline facilities from accumulated snow or ice.

2008

73 FR 11695 - ADB-08-02

Issues Related to Mechanical Couplings Used in Natural Gas Distribution Systems

This notice updates information provided in Advisory Bulletin ADB–86–02 and advises owners and operators of gas pipelines to consider the potential failure modes for mechanical couplings used for joining and pressure sealing two pipes together.

2007

72 FR 51301 -

ADB-07-02

Updated Notification of the Susceptibility to Premature Brittle-like Cracking of Older Plastic Pipe

PHMSA is issuing this updated advisory bulletin to owners and operators of natural gas pipeline distribution systems concerning the susceptibility of older plastic pipe to premature brittle-like cracking.

Threat Identification – NTSB Recommendations &

Letters

YearNTSB Report

Number

Recommendation Number

Report Type Deaths Injuries Root Cause(s)

1991 P96-016Safety Recommendation

2 3third party, failed PE coupling


0 0 regulator failure

1990PAR-92-

01 Accident Report 2 24 operating error


1 9

ground movement caused by leaking water main, cast iron graphitization


2 0mechanical coupling failure

1988PAR-89-

01 Accident Report 0 4 operating error

§192.1007 (c) Evaluate and Rank Risk

§192.1007 (c) Evaluate and rank risk. An operator must evaluate the risks associated with its distribution pipeline. In this evaluation, the operator must determine the relative importance of each threat and estimate and rank the risks posed to its pipeline. This evaluation must consider each applicable current and potential threat, the likelihood of failure associated with each threat, and the potential consequences of such a failure.

Evaluation & Ranking Risk

Possible Methodologies

• Data Centric Risk Evaluation and Ranking Methodology

• Subject Matter Expert (SME) Risk Evaluation and Ranking Methodology

• Blended Risk Evaluation and Ranking Methodology

Evaluation & Ranking Risk

Risk Evaluation by Geographical Regions

• Begin with the End in Mind – Targeting Mitigation

• Data availability may be the leading factor

• Going too small may result in poor results

• Going too large may not yield the ability to target mitigation

Data Centric Risk Evaluation

Frequency of FailureUse of Historical Leak Repair and Incident History•Uses data the operator already collects•Provides data on root cause•Outcome easy to validate based on actual experience•Confidence when using to target mitigation

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

A1 B4 C3 B3 C2 A4 B1 A3 A2 B2 C4 C1

Leak

s /

mile

/ y

ear

Region

Projected Leak Frequency - Bare Steel MainsCorrosion Leaks per Mile of Bare Steel per Year

(FOF Level 1 - Mains)

Data Centric Risk Evaluation

Implementation of the NGA/SGA DIMP Model – A Case Study

Wednesday 9:15 AM – 10:00 AM

Rob McElroy – New Century Software

(Palm Ballroom)

SME Risk Evaluation

• An approach for those who lack Data

• Risk Scores developed from both likelihood and consequence

Primary Threat

Sub-Threat

Relative Freq of Failure (FOF) Score FOF Score general descriptor

FOF Score

Selected by SME(s)

SME Comment(s)

Other Outside Force Damage

Vehicle Damage to Riser / Meter

0 No history of damage to meters or risers

1 Leaks or damage are infrequent, active program in place to relocate at-risk meters/risers

2 Leaks or damage are moderate in number, damaged meters/risers are relocated as appropriate

3 Frequent leaks or damage, mitigation not in place or not effective

§192.1007 (d) Identify and Implement Measures to address risks

§192.1007 (d) Identify and implement measures to address risks. Determine and implement measures designed to reduce the risks from failure of its gas distribution pipeline. These measures must include an effective leak management program (unless all leaks are repaired when found).

Validation of Leak Management Program Effectiveness

Program Element

Reference to Requirement Established in the Standard or

Procedure

Qualification/Training requirements for personnel conducting leak survey

Auditing and Quality Assurance of Leak Survey Equipment

Criteria for leak severity classification

Established Frequency of Leak Survey in Business Districts, at intervals not exceeding 15 months, but at least once each calendar year.

Established Frequency of Leak Survey for Cathodically Unprotected Lines subject to §192.465(e) on which electrical surveys for corrosion are impractical, at least once every 3 calendar years at intervals not exceeding 39 months.

Established Frequency of Leak Survey of Remaining Lines at least once every 5 calendar years at intervals not exceeding 63 months.

Hazardous Leaks Requiring Immediate Repair – Ongoing action required

Non-hazardous Leaks Requiring Scheduled Repair – Time limit is established to Eliminate Leak

Non-Hazardous Leak NOT requiring scheduled repair– Monitoring Requirements established

Records and Data Management procedures defined

Performance Metrics established

Key Performance Metric 2010 2011 2012% of Leak Survey Completed within the time allowed by Standard

% of Leaks Eliminated or Repaired within the time allowed by Standard / Procedure

% of Leak Survey Devices audited that fully comply with calibration and maintenance requirements

Report Results

•Excess Flow Valves Installed

•Number of hazardous leaks either eliminated or repaired, categorized by cause

•Number of excavation damages*

•Number of excavation tickets

•Total number of leaks either eliminated or repaired, categorized by cause

•Information related to failure of compression couplings, excluding those that result only in nonhazardous leaks (effective Jan 1, 2011)

Number of Excavation Damages*

New Gas Distribution Annual Report FormJune 28, 2010 Federal Register

Questions??

[email protected]

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