2017 KGA 10th Annual Expo Melissa Holbrook KY PSC Email: melissac.holbrook@ky.gov Cell: 502-229-7542 Lexington, KY
Topics PSC Staff Update PHMSA Updates Inspections Incident Notification Inspector Findings 2017 Outlook
Pipeline Safety Branch Chairman-Michael J. Schmitt Vice Chair-Robert Cicero Commissioner-Daniel Logsdon
Division of Inspections Talina Matthews, Executive Director John Lyons, Division Director James Rice, Assistant Director/Gas Coordinator Pipeline Safety Bill Aitken, Utility Investigator Melissa Holbrook, Utility Investigator Steve Samples, Utility Investigator Joel Grugin, Utility Investigator Mark McCullough, Utility Investigator
2017 PHMA Updates ??? Federal Incident Reporting 1 Hour Underground Storage OQ Excess Flow Valves PSC Received PHMSA Letter
PHMSA Forms & Checklist www.phmsa.dot.gov/pipeline/library/forms
2017 Inspections Standard Inspection 3 year cycle /Risk Rank Procedures O&M Activities Annual Report Annual Report Financial Incidents Construction Records Damage prevention Drug/ Alcohol Plan DIMP Implementation/ 5 Year Evaluation NTSB Questions Operator Qualification plan/records/protocol 9 Cyber Security
After The Inspection Checklist will be reviewed Inspector will write Cover Letter Inspector Must send Report to an Officer of Company. Report will be sent within 30 days of inspection. Watch for report in mail
Report with Deficiencies Review Report in Detail Look for Response date on cover letter Respond to PSC Staff (Inspector) within Requested time. After second notice no response referred to legal.
Incident Notification Incident means any of the following events (1) An event that involves a release of gas from a pipeline or of liquefied natural gas, liquefied petroleum gas, refrigerant gas, or gas from an LNG facility, and that results in one or more of the following consequences: or gas from an LNG facility and (i) A death, or personal injury necessitating in-patient hospitalization; or (ii) Estimated property damage of $50,000 or more, including loss to the operator and others, or both, but excluding cost of gas lost; , including cost of gas lost, of the operator or others, or both, of $50,000 or more. (iii) Unintentional estimated gas loss of three million cubic feet or more; (2) An event that results in an emergency shutdown of an LNG facility. Activation of an emergency shutdown system for reasons other than an actual emergency does not constitute an incident. (3) An event that is significant, in the judgment of the operator, even though it did not meet the criteria of paragraphs (1) or (2) of this definition.
State vs. Federal Requirements Section 3. Telephonic Notice of Certain Incidents. (1) At the earliest practicable moment but no later than two (2) hours following discovery, each utility shall give notice to the commission in accordance with subsection (3) of this section of any incident that: (a) Is reported to USDOT pursuant to 49 CFR Part 191, Federal Pipeline Safety Regulations. (b) Requires taking any segment of pipeline or mains out of service. (c) Results in gas ignition. (d) Causes estimated damage to property of the utility, or others, or both, of $25,000 or more. (e) Results in the loss of service to forty (40) or more customers for four (4) or more hours. (f) Causes the loss of a sizable amount of gas. (g) Received extensive news coverage, or in the judgment of the utility is significant, even though it does not meet the criteria of paragraphs (a) through (g) of this subsection. (2) A utility need not give notice of an incident that meets only criteria of subsections (1)(b) and (c) of this section if it occurred solely as a result of, or in connection with, planned or routine maintenance or construction.
Know Your Regulations Know if you are under state or federal regulations. Review your Incident Procedures Review Procedures and Requirements with Field and office personal. Put appropriate contact information in Cell Phone Contacts. PSC # 502-782-7903 or email: Pipeline.Safety@ky.gov
National Emergency Response Center Reporting 191.5 Telephonic notice of certain incidents. Immediate notice of certain incidents. (a) At the earliest practicable moment following discovery, each operator shall give notice in accordance with paragraph (b) of this section of each incident as defined in §191.3. (b) Each notice required by paragraph (a) of this section must be made to the National Response Center either by telephone to 800-424-8802 (in Washington, DC, 202 267-2675) or electronically at http://www.nrc.uscg.mil and must include the following information: (a) of this section shall be made by telephone to 800-424-8802(in Washington, DC, 267-2675) and shall include the following information: (1) Names of operator and person making report and their telephone numbers. (2) The location of the incident. (3) The time of the incident. (4) The number of fatalities and personal injuries, if any. (5) All other significant facts that are known by the operator that are relevant to the cause of the incident or extent of the damages.
Incident Reporting Operator not reporting Incident Operator not reporting within the 2 hour requirement (State) Not Reporting to National Response Center Not Sending 30 Day Report to PHMSA Not Providing Detailed 30 Day Report (State) Not Providing required documentation
2017 PSC Focus Operators Gas Loss Operators Leak Surveys Repeat Violations Excessive Violations No Response or Action Taken
2016 Top Five Deficiencies Public Awareness Patrolling Distribution Operator Qualification Valve Maintenance Distribution Emergency Plans
2016 / 2017 Top Findings Not maintaining records Not Properly documenting leakage surveys No Welding Procedures No Pipe Fusion Records Contractors not properly Operator Qualified Employees not proper OQ Qualifications Employees not properly trained 5 year DIMP Evaluation Not doing what plan says
PSC Investigators Top Field Issues Trench Safety Accidental Ignition Customer/Main Piping Meter / Regulator Station Protection Proper Training OQ
Personal Protective Equipment (PPE) During Field Work Fire extinguishers Breathing apparatus Safety harnesses Hard hat Ear protection devices Combustible gas detectors Oxygen deficiency indicator and other such equipment in the work area.
192.605 (b) (9) Taking adequate precautions in excavated trenches to protect personnel from the hazards of unsafe accumulations of vapor or gas, and making available when needed at the excavation, emergency rescue equipment, including a breathing apparatus and, a rescue harness and line.
192.751 Prevention of Accidental Ignition Each operator shall take steps to minimize the danger of accidental ignition of gas in any structure or area where the presence of gas constitutes a hazard of fire or explosion, including the following: (a) When a hazardous amount of gas is being vented into open air, each potential source of ignition must be removed from the area and a fire extinguisher must be provided.
Ignition Sources Smoking / Open Flames Communication Equipment Portable electrically powered tools and equipment Internal Combustion Engines Static Electricity on Plastic Pipe
Ignition Sources
Customer Piping For dangerous conditions. If a dangerous condition relating to the utility's service which could subject any person to imminent harm or result in substantial damage to the property of the utility or others, is found to exist on the customer's premises, the service shall be refused or terminated without advance notice. The utility shall notify the customer immediately in writing and, if possible, orally of the reasons for the termination or refusal.
Customer Piping
Customer Piping
Customer Piping
Customer Piping
Exposed Plastic Mains
Exposed Plastic Mains
192.317 Protection from hazards. (b) Each above ground transmission line or main, not located offshore or in inland navigable water areas, must be protected from accidental damage by vehicular traffic or other similar causes, either by being placed at a safe distance from the traffic or by installing barricades
Meter Protection 192.353 Customer meters and regulators: Location. a) Each meter and service regulator, whether inside or outside a building, must be installed in a readily accessible location and be protected from corrosion and other damage, including, if installed outside a building, vehicular damage that may be anticipated. However, the upstream regulator in a series may be buried.
2017 Outlook Hiring New Inspector NAPSR Meeting PHMSA KY State Audit KGA Best Practices Control Room Mgt.
Pipeline Safety Contact Telephone: 502-782-7903 Email: Pipeline.Safety@ky.gov
Pipeline Safety Investigator Gas Pipeline Safety Branch Division of Inspections Melissa Holbrook 211 Sower Blvd. Frankfort, KY 40602 http://psc.ky.gov Ph: (502) 782-2603 Cell: 502-229-7542 Fax: (502) 564-1582 MelissaC. Holbrook@ky.gov