1. What’s next for Gas Utilities?
Paul J. Roberti
Chief Counsel
US DOT, PHMSA
November 12, 2018

2. Distribution Lines: Balancing Costs and Safety Issues
Aging Infrastructure
Replacement of Cast Iron and Bare Steel Pipe
Gas Distribution Integrity Management Implementation and Continuous Improvement
Regulatory Goals

3. PHMSA Regulated Pipeline Facilities OPS and State Partners CY 2017
Gas Distribution (Mains & Services)
Total Miles: 2,235,727
Percentage miles: 80%
Number of Operators: 1,362

4. Distribution Lines and Safety: Causes of Incidents and Concerns

5. Gas Distribution Significant Incidents
CY 2017 Leading Causes:
Significant Incident - an incident which causes:
Outside Force Damage (29%)
Fatality or injury requiring in-patient hospitalization
Excavation Damage (25%)
$50,000 or more in total costs
Highly volatile liquid releases of 5 barrels or more or other liquid releases of 50 barrels or more
Liquid releases resulting in an unintentional fire or explosion
data as-of

6. Gas Distribution Significant Incidents per Million Miles (2005 – 2017)
Rate has fluctuated since overall decrease since 2005 is 30%
Rate with evacuation has decreased 28% since 2005
Rate with public property damage has decreased 49% since 2005
Data as of:

7. Aging Infrastructure
Parts of Part 192 where operators are required to take actions to reduce risks

8. Aging Infrastructure
In 2011, PHMSA issued a Call to Action to accelerate the repair, rehabilitation, and replacement of the highest-risk pipeline infrastructure.
PHMSA provides an annually-updated online inventory of high-risk pipeline infrastructure by state.
Highlights efforts to replace iron and bare steel gas distribution pipelines and shows trends in pipeline miles by decade of installation.

9. Gas Distribution Miles by Decade Installed (2005 – 2017)
30% of gas distribution systems were installed Pre-1970
Miles of pipeline system installed Pre-1970 has declined 18% since 2005
Data as of:

10. Cast Iron and Bare Steel History
Pipelines constructed of cast and wrought iron, as well as bare steel, are among those pipelines that pose the highest-risk.
The degrading nature of iron alloys, the age of the pipelines, and pipe joints design have greatly increased the risk involved with continued use of such pipelines.
Approximately 97 percent of natural gas distribution pipelines in the U.S. were made of plastic or steel at the end of The remaining 3 percent is mostly iron pipe.

11. Cast Iron and Bare Steel History
Cast and wrought iron pipelines were originally constructed to transport manufactured gas beginning in the 1870s and 1880s, with cast iron becoming more popular in the early 1900s.
In 1970, PHMSA began collecting data about gas pipelines mileage categorized by pipe material type.
In 1983, gas distribution pipeline operators reported 61,536 miles of cast iron and 4,371 miles of wrought iron pipe. Operators began submitting merged data for the two beginning in 1984.

12. Gas Distribution Cast and Wrought Iron (2005 – 2017)
Cast and Wrought Iron Main Miles have decreased 38% since 2005
Cast and Wrought Iron mains are less than 2% of the total gas distribution main miles.
Cast and Wrought Iron Service Count data quality efforts are underway
Less than .1% of all gas distribution services are Cast and Wrought Iron.
Data as of:

13. Aging Pipe Replacement
The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 calls for DOT to conduct a state-by-state survey on the progress of cast iron pipeline replacement.
Nineteen states have completely eliminated cast or wrought iron natural gas distribution lines within their borders.
Replacement programs to transition to plastic piping.
For updates on the states’ progress, contact information and incident and mileage data, the public should visit PHMSA’s state pipeline profiles.

14. Incident and Consequence Analysis
Gas distribution incident reports (excluding those caused by leaks beyond the customer meter) for 2005 through 2017 show the following:
10.6 percent of the incidents occurring on gas distribution mains involved cast iron mains. However, only 2 percent of distribution mains are cast iron.
37 percent of the cast/wrought iron main incidents caused a fatality or injury, compared to only 20 percent of the incidents on other types of mains.
41 percent of all fatalities and 19 percent of all injuries on gas distribution mains involved cast or wrought iron pipelines.

15. Gas Distribution Integrity Management Program (DIMP): Inspection Observations, Results, and Findings

16. DIMP Regulations
PHMSA published the final rule establishing integrity management requirements for gas distribution pipeline systems on December 4, 2009 (74 FR 63906), with an effective date of February 12, 2010 (49 CFR Part 192, Subpart P).
The DIMP regulations are performance based to allow operators to implement their DIMP in the most efficient and effective manner to improve pipeline safety.
Under the DIMP regulations, operators, including those with cast/wrought iron, must have knowledge of the specific characteristics of the pipe and environments where graphitization could be severe. Operators must also evaluate past leak history and monitor cast/wrought iron pipe during excavations as part of maintaining integrity.
Parts of Part 192 where operators are required to take actions to reduce risks

17. DIMP Implementation
Operators should treat DIMP as a tool to analyze needs and progress, not as a regulatory exercise or a book on the shelf.
Operators are required to know and understand their systems and the environments in which they operate.
The DIMP should culminate in a ranked/prioritized list of threats, risk reduction measures being implemented to address risks, and performance measures for program effectiveness.
An operator’s DIMP must mature and be continuously improved to fit the unique operating environment - a continuous learning experience!

18. Employee Training Concerns
Inconsistent training of operator personnel regarding DIMP requirements.
Lack of awareness of DIMP by all operator personnel – not just at the headquarter or compliance level.
Data quality is a common concern, and an appropriate level of resource allocation is required.
Outdated field data acquisition forms
Incomplete forms with obvious errors
Data cleanup and scrubbing is often required

19. Employee Retention Concerns
Vacancies created by an aging workforce (turn-over) have created voids in operating knowledge of pipeline systems, and trained personnel have not always been available for inspections.
Retention of trained and qualified employees has been identified as a common issue requiring transition planning and training.
Documentation of a pipeline system and operation, maintenance & inspection procedures are important to retain knowledge.

20. Potential Threats Must Be Considered
Over pressurization events
Regulator malfunction or freeze-up
Cross-bores into sewer lines
Materials, Equipment, Practices, etc. with performance issues
Vehicular or Industrial activities
Incorrect maintenance procedures or faulty components
Mechanical fitting failures (Vintage Plastic and Steel)
Operator error/quality of workmanship
Age of system and equipment
Electrical arcing onto the gas systems
Other potential threats specific to the operator's unique operating environment

21. An Unique Operating Environment
There are many factors that affect the safe operation and integrity of pipeline system
These factors are changing over time – based on age, environmental changes or other factors:
Increases in leakage rates based on location or pipe material or construction era
Decreasing efficiency in corrosion protection systems
Changes in apparent causes of leaks and hazardous leaks
Data integrated from lessons learned from field personnel
Etc…

22. Improving Safety through Performance Measures and Trending Analyses

23. “What gets measured, gets done.”
To ensure risk mitigation measures are improving safety, performance must be measured and trended.
There are many websites that provide performance monitoring for Stakeholders at the national, regional, and operator level:
PHMSA Data and Statistics Overview -
PHMSA National Pipeline Performance Measures -
PHMSA DIMP Website –
PHMSAState Pipeline Performance Metrics -

24. Trends in Gas Distribution Incidents by Cause - National Data -
ALL REPORTED
Total
Incident Cause Type
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
ALL OTHER CAUSES 15 23 22 16 21 14 7 9 12 13
193
CORROSION 2 3 1 5 4 30
EXCAVATION DAMAGE 67 49 53 35 43 24 31 37
501
INCORRECT OPERATION 6 8 79
MATERIAL/
WELD/EQUP FAILURE 11 17
151
NATURAL FORCE DAMAGE
127
OTHER OUTSIDE FORCE DAMAGE 51 41 62 60 50 39 34 32
543
Grand Total
168
140
163
144
156
120
117 90
104
107
118
108
1,624

25. National Trends in Gas Distribution Leaks
Leaks Eliminated
Hazardous Leaks Eliminated

26. Significant Gas Distribution Incidents - Nationally-
Data indicates an upward trend for significant incidents over the last 8 years since DIMP regulations came into effect.

27. Current Regulatory Topics for Distribution Operators

28. Current Pipeline Safety Rulemakings

29. Regulatory Reform Goals
Provide regulatory relief from programs that do not significantly improve safety in relation to the cost to the operator.
Allow operators to focus resources on heightened safety concerns.
Regulatory agenda considers NTSB recommendations.

30. Regulatory Reform Goals
Identified potential areas of reform based on comments submitted in response to 82 FR Oct. 2, 2017) requesting comment on existing regulations that may be eligible for repeal, replacement, suspension, or modification without compromising safety.
Considering comments such as:
Mechanical Fitting Failure reports;
Master meter requirements in DIMP;
Farm tap requirements in DIMP.

31. Current NTSB Investigations of Incidents in Gas Distribution Systems
Minneapolis, Minnesota – August 2, 2017 – awaiting report
Dallas, Texas – February 23, 2018 – awaiting report
Safety Recommendations on PermaLock Mechanical Tapping Tees issued June 18, 2018 – Millersville, Pennsylvania – July 2, 2017 – awaiting report
Response to Event in Lawrence, MA – September 13, awaiting report

32. Lessons Learned Programs
NTSB has asked - How did this happen and Why did the DIMP not identify the “threat” as an issue?
Similar to what Congress asked in forming the Voluntary Information Sharing (VIS) Committee – Why do we have so many failures following in-line inspections?
VIS Committee Learning - Implementing lessons learned programs support development of a safety culture:
Corrective Action Programs & Near Miss Reporting
FAA – Aviation Safety Alert Programs
FRA - Confidential Close Call Reporting
Quantitative Data Programs take longer to implement.

33. Questions?