1. Update on regulations and SIF programs American Public Gas Association
the voice and choice of public gas
Update on regulations and SIF programs
John Erickson, P.E.
American Public Gas Association

2. Who We Are ~1000 community-owned gas systems Over 700 are APGA members
37 states
~5 Million Customers
~21,000 Employees
~120,000 Miles of Main
Systems size: 38 to ~500,000 meters
Largest: Philadelphia with ~ 500,000 meters
Smallest: Freedom, OK with 38 meters

3. Recent Regulatory Activity
Construction inspection Final rule
Transmission Integrity proposed rule
Public Awareness SWOT report
Excess Flow Valves for multi-family residential and commercial service lines proposed rule
Plastic pipe proposed rule
Operator Qualification proposed rule
Incident Notification proposed rule

4. Construction Inspection
Final rule published 3/11/15
Existing : “Each transmission line or main must be inspected to ensure that it is constructed in accordance with this part.”
Added: Operator personnel may not perform a required inspection if the operator personnel performed the construction task requiring inspection.
Also changed “part” to “subpart” (Subpart G)

5. Construction Inspection
Also added: “Nothing in this section prohibits the operator from inspecting construction tasks with operator personnel who are involved in other construction tasks”
PHMSA certified no impact on small entities
Unclear if a two person crew can inspect each other’s work
APGA petitioned PHMSA to clarify
PHMSA formed a working group to advise it
PHMSA has indefinitely stayed effective date

6. Transmission proposed rule
Only 62 municipal gas systems have “transmission” lines (2,700 miles, total)
50 percent is 8 inches diameter or less
300 miles are between 1 and 4 inches diameter
Virtually all municipal gas systems receive gas from transmission pipelines, so the cost to pipeline operators is a concern

7. Gate station

8. Lorimor, IA 2” steel – schedule 40 150 psig – < 1% SMYS
Class 1 – miles
2” steel – schedule 40
150 psig – < 1% SMYS
198 meters – Population 360
Revenues $113,871
PIR 17 feet

14. Transmission line definition
Transmission line means a pipeline, other than a gathering line, that: (1) Transports gas from a gathering line or storage facility to a distribution center…
PHMSA has proposed to define “distribution center” as “a location where gas volumes are either metered or have pressure or volume reductions prior to delivery to customers through a distribution line.”
Will that make the Lorimor line distribution?

15. Concerns
Rule should not apply to lines classified as transmission other than due to SMYS
Rule should not apply to lines operating at less than 30% SMYS
Changes to Part 192 sections that also apply to distribution should be corrected (e.g. Appendix D)

16. Public Awareness SWOT Report
Public Awareness Program Working Group created in September 2013
Objective: To study the current state of pipeline public awareness efforts, including:
Reviewing pipeline public awareness data
Identifying relevant topical review areas
Performing “strengths, weaknesses, opportunities, and threats” (SWOT) analyses for each topical review area
Report of key findings issued May 16, 2016

17. Key Findings
Fundamental differences between interstate pipelines and distribution systems affect how public awareness programs are developed and implemented

18. Key Findings
Collaborative public awareness efforts among stakeholders could be effective with the public
The national 811 “Call Before You Dig” number is a simple and effective message
There are still weaknesses in the overall effectiveness of pipeline operators’ outreach to emergency responders
Measuring operator public awareness program effectiveness was challenging

19. Key Findings
Affected stakeholders of small distribution pipeline operators, particularly municipally-owned systems, have unique awareness needs
“The level of awareness among these audiences is often relatively high due to a deep level of market penetration and decades of receiving services from the operators. This makes improving stakeholder awareness challenging.”

20. Would Recognize Gas Smell
Customers
Non-Customers

21. Excess Flow Valves Proposed July 15, 2015
Would require EFVs on new and replaced service lines to:
Multi family residential up to 1,000 cfh
Commercial customers up to 1,000 cfh
Install curb valves if > 1,000 cfh
Notification about EFVs when new customer takes over an existing account, installing EFV if requested by customer

22. Plastic Pipe Proposed May 21, 2015 Tracking and traceability
Higher limits for PE, PA-11 and PA-12
Prohibit socket fusion > 1 ¼” diameter
No permanent repairs using leak repair clamps
Regulations for trenchless installation
~ 20 more proposals
Changes suggested by TPSSC

23. Operator Qualification
Proposed July 10, 2015
Definition of covered task to include construction and emergency response tasks
Redefines KSA’s
Redefines “qualified”
Span of control, MOC and evaluator criteria
Program effectiveness assessment
Changes recommended by TPSSC

24. Incident Notification
Included in the July 10, 2015 OQ proposal
Initial call to the NRC must be no later than 1 hour after “confirmed discovery”
Must include estimated product (gas) lost
TPSSC recommended deleting estimate of gas lost from gas incident reporting
Must be included in the 48 hour confirmation call

25. QUESTIONS?

26. Security & Integrity Foundation (SIF)
Independent of APGA
Assist small operators to operate safe gas distribution systems
“Small operators” include —
Natural gas utilities
Master meter, and
Propane piping systems
For 10 years funded through a cooperative agreement with PHMSA
Is now self-sufficient

27. SIF Programs Operator Qualification Evaluations
Operation and maintenance procedures
SHRIMP
Operator Qualification training
O&M Manual creation tool
OQ plan creation tool
Public Awareness plan creation tool

28. Changes To SHRIMP
We continually modify SHRIMP based on feedback from regulators and users
There have been 47 updates
Current SHRIMP version is
A DIMP plan will only include updates if it has been re-generated with the latest version
Changes are described in Announcements displayed when you next log in to SHRIMP
s notices are sent for major revisions

29. Existing and Potential Threats
Rule requires that DIMP plans consider existing and potential threats
SHRIMP interviews address both.
For example, for corrosion threat:
Corrosion leaks, metal loss = Existing threat
Stray currents, low CP = Potential threat
SHRIMP written plans will be modified to separately list existing and potential threats

30. Interacting Threats
“Two or more threats acting on a pipe or pipe segment that increase the probability of failure to level significantly greater than the effects of the threats acting alone” Kiefner & Associates, Inc.
Example: The presence of cast iron or brittle plastic pipe in an area prone to earth movement

31. Interacting Threats The rule does not mention interacting threats
However, SHRIMP’s risk ranking model includes questions regarding interacting threats
For example: Low CP levels and stray currents raise the probability of corrosion, but do not affect the pipeline segment’s risk of excavation damage

32. Interacting Threats Not all threats are interacting
Interacting threats are uncommon on low stress distribution lines

33. Form 24
Form 24 is for auditing whether the operator has followed through with all the actions required by its written DIMP plan
SHRIMP includes an implementation plan that summarizes all these actions
Some items in form 24 required changes to SHRIMP’s written DIMP plan template

34. Form 24
For example, item 29. Periodic Evaluation - If any established performance measures indicated an increase in risk beyond an acceptable level (as established in the DIMP plan), were new risk reduction measures implemented along with their associated performance measures?
Chapter 8 of the SHRIMP Plan template is being revised to define unacceptable increase in risk

35. Other SIF programs Also available: Under development:
Drug and alcohol plan creation tool
Under development:
Operations and maintenance manual creation tool
Public awareness plan creation tool
Operator qualification plan creation tool

36. Questions?