Gas Utility Operations Best Practices Program August 12-14, 2014 Gas Utility Operations Best Practices Program Leak Management Detroit, MI Reporting and Tracking Above Ground Leaks Mike Bellman, AGA

www.aga.org Note: The AGA Operations Best Practices Program is intended to highlight how particular companies may address a specific operational issue and may not include all of the data related to a highlighted practice. The need to implement and the timing of any implementation of highlighted practices will vary with each operator. Each operator serves a unique and defined geographic area and their system infrastructures vary widely based on a multitude of factors, including, condition, engineering practices and materials. Each operator needs to evaluate highlighted practices in light of their system variables. Not all highlighted practices will be applicable to all operators due to the unique set of circumstances that are attendant to their specific systems. Companies are not ranked through this program and no one practice is identified as the best for a particular topic. Copyright & Distribution: Copyright © 2014 American Gas Association. All rights reserved. The AGA Gas Utility Operations Best Practices Program publications are copyrighted, confidential and proprietary to AGA and only available on the member-restricted side of the AGA website. Permission to reproduce or transmit in any form or by any means, electronic or mechanical, including photocopying or recording, or by any information storage and retrieval system any publication or portion of a publication must be obtained in writing from the AGA General Counsel’s Office, GCO@aga.org. AGA Full, Limited and International Members are granted a limited license to reproduce this publication for internal business purposes but not for regulatory or civil matters.

Hazardous Above Ground Leaks: AGA developed Definition October 16, 2009  A Hazardous Aboveground leak is an unintentional escape of gas from above ground piping or related gas facilities that requires immediate make-safe action, because: On Outside Piping, it: can be seen, heard, or felt (e.g.- causes the blowing-off of leak detection soap); and is in a location that may endanger the general public or property (e.g. - requires an immediate evacuation to protect public safety). On Inside Piping, it: is in a location that may endanger the general public or property (e.g. - requires an immediate evacuation to protect public safety) or generates a reading of 20% LEL or more in the general atmosphere of the structure.

Hazardous Above Ground Leaks - Definition October 16, 2009  What is a “Reportable Aboveground Leak”? – An aboveground leak determined to be hazardous based on the criteria defined above is reportable.   Minor escapes of gas (non-hazardous releases) at threads on sound piping or at fittings that are detectable only with instruments in direct proximity or that give only slight indications with leak detection soap need not be considered as leaks if they could be eliminated by lubrication, adjustment or tightening, even if the operator elects to reconstruct the piping or replace parts in order to eliminate the minor escape of gas.

Hazardous Above Ground Leak? Assume this regulator fails and is blowing gas Would you evacuate? Is this a reportable leak?

Hazardous Above Ground Leak? Assume corrosion leak on threads below meter valve Would you evacuate? Is this a reportable leak?

Hazardous Above Ground Leak? Home owner built a meter enclosure Is a leak on this facility reportable? Is this an inside leak or an outside leak?

Hazardous Above Ground Leak? Assume that this meter set regulator is blowing with no possibility of migrating to an enclosed building. However, the Fire Department has responded and is controlling access to the area. Is this leak reportable?

Hazardous Above Ground Leak? A leak at your gate station has been called in by a member of the public. Access to the site is controlled through a locked fence. Is this Leak reportable?

Do you receive a report of these? Gas Emissions:  Minor escapes of Gas that can be eliminated by lubrication, adjustment or tightening. Do you receive a report of these? Do you use this definition for both above ground and below ground “gas emissions”? Are they tracked? Can you identify, for DIMP, any trends in the need to tighten a particular manufacturers fittings?

Do you conduct failure analysis on: Meter Valves, Regulators, Meters? Analyzing Failures  49CFR192.617 requires analyzing failures including selection of samples of failed equipment for laboratory examination. Do you conduct failure analysis on: Meter Valves, Regulators, Meters? Do you have a process to match the results of the analysis to your leak records? What if the failure did not reach the level of a reportable leak?

“Failure ….. to comply with 49 C.F.R. § 192 .617, Analyzing Failures  49CFR192.617 requires analyzing failures One state violation: “Failure ….. to comply with 49 C.F.R. § 192 .617, by incorrectly reporting the leak cause on Company leak repair forms”

www.aga.org The American Gas Association, founded in 1918, represents more than 200 local energy companies that deliver clean natural gas throughout the United States. There are more than 71 million residential, commercial and industrial natural gas customers in the United States, of which 92% — more than 65 million customers — receive their gas from AGA members. Today, natural gas meets almost one-fourth of the United States’ energy needs.