2017 LGA 191/192 & 195 Pipeline Safety Conference Presented by: Wallace Jones Director, Gas Pipeline Safety Division Alabama Public Service Commission
Issu Issues tha that GPS/PSC GPS/PSC St Staf aff ar are ha havi ving ng wi with Pip Pipelin line Oper Operator ors
“We ALL have Issues”
But what are we going to do to address our Issues?
What’s wrong with this picture? How do we fix this?
We get the spare tire out right? Solution: Inspect your spare every time you service your vehicle
What about this one?
Wh What at do do we we do do no now? w? • Call 811? • Do we call our buddy and tell him we might be late for the golf game? • Tell your boss you don’t work overtime? • Do I call the fire department first or the gas company first? • Should I notify PHMSA or the state regulatory authority?
PROBLEMS FOUND
192.605 Each operator shall Prepare and Follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response
Refer to your O&M and Emergency Plan • 192.605(a) Manuals must be REVIEWED and UPDATED by the operator at intervals not exceeding 15 months, but at least once each calendar year. Also Submit to APSC • Appropriate parts of the manual Must be kept at locations where operations and maintenance activities are conducted.
How do we know these Manuals aren’t being Reviewed, Revised or Followed? • Operators are not taking into consideration recommendations from their inspector • Inspector handwriting and notes are still in plans • Operator can’t provide Procedures on Construction Sites • Operators are performing covered tasks different than the procedure allows
Items that are late or not submitted at all • Gas DOT Reports March 15 • Liquid DOT Reports June 15 • Incidents (Reportable or Not) Especially if Media is Involved • Mechanical Fitting Failure
At Atmospheric Corr Corrosi osion 192.481 192.481 (a) Each operator must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows:
Atmospheric Corrosion continued 192.481 • If the pipeline is located: Onshore Then the frequency of inspection is: At least once every 3 calendar years, but with intervals not exceeding 39 months • If the pipeline is located: Offshore Then the frequency of inspection is: At least once each calendar year, but with intervals not exceeding 15 months
At Atmospheric Corr Corrosi osion continued nued 192.481 192.481 • (b) During inspections the operator must give particular attention to pipe at soil ‐ to ‐ air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. • (c) If atmospheric corrosion is found during an inspection, the operator must provide protection against the corrosion as required by Sec. 192.479.
Cathodic Protection • Isolated Services and Mains • Location of Test Points • Deficiencies
Cathodic Protection • (a) Each pipeline all parts of those physical facilities through which gas moves in transportation, including pipe, valves, and other appurtenance attached to pipe, compressor units, metering stations, regulator stations, delivery stations, holders, and fabricated assemblies. that is under cathodic protection must be tested at least once each calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic protection meets the requirements of §192.463. However, if tests at those intervals are impractical for separately protected short sections of mains or transmission line a pipeline, other than a gathering line, that: (1) Transports gas from a gathering line or storage facility to a gas distribution center, storage facility, or large volume customer that is not down ‐ stream from a gas distribution center; (2) operates at a hoop stress of 20 percent or more of SMYS; or (3) transports gas within a storage field., not in excess of 100 feet (30 meters See Customer meter, Meter set assembly. (Guide definition)), or separately protected service line a distribution line that transports gas from a common source of supply to an individual customer, to two adjacent or adjoining residential or small commercial customers, or to multiple residential or small commercial customers served through a meter header or manifold., these pipelines may be surveyed on a sampling basis. At least 10 percent of these protected structures, distributed over the entire system must be surveyed each calendar year, with a different 10 percent checked each subsequent year, so that the entire system is tested in each 10 ‐ year period.
Cathodic Protection Mapping 192.491(a) • (a) Each operator shall maintain records or maps to show the location of cathodically protected piping, cathodic protection facilities , galvanic anodes, and neighboring structures bonded to the cathodic protection system. Records or maps showing a stated number of anodes, installed in a stated manner or spacing, need not show specific distances to each buried anode.
Cathodic Protection Deficiencies 192.465(d) • (d) Each operator shall take prompt remedial action to correct any deficiencies indicated by the monitoring.
REVIEW REVIEW Wh What at ar are som some Issues Issues we we ar are ha having ving wi with Oper Operator ors • Operators are just creating new cover sheets for programs without actually reviewing or updating the programs • Operators not taking any of the inspector recommendations into consideration prior to their next inspection • Operators not providing every employee a copy of the manuals • Operators are not notifying their inspector of incidents whether or not it’s reportable ( especially when the media is present )
Issues continued • Operators not following their own procedures • Atmospheric Corrosion • Cathodic Protection on Isolated Section of Pipe
Operators are not following what their Emergency Plan and Public Awareness Plans have written into their program in regards to emergency responders and school systems.
Emergency Plan Issues
Does the Emergency Plan meet the following requirements of § 192.615? 2. Has the plan been reviewed and updated at intervals not a. exceeding 15 months but at least once each calendar year? Ref. §192.605(a). Does the Plan provide for receiving, identifying, and 1. classifying notices of events which require immediate response? Ref. § 192.615(a)(1). Has the Operator established and maintained adequate 2. means of communication with appropriate fire, police, and other public officials? Ref. § 192.615(a)(2).
Have responsible supervisors been trained and b. furnished the 13 parts of this part? When was the most current training? Ref. 192.615(b). Has Operator established and maintained liaison with c. appropriate public officials? Ref. 192.615(c).
Public Awareness Plan Issues
Some Programs Operators are using to address the Appropriate Stakeholders APACT (Alabama Pipeline Awareness Cooperative Training ‐ Conducted by Alabama 811 and sponsored by local operators) Paradigm CGA (Common Ground Alliance) Other
Does the Operator's Public Awareness Program meet the requirements of 35. §192.616? Has the Operator evaluated the PAP for effectiveness as described in a. RP1162? Did the operator deliver messages to the following b. stakeholders: Affected 1. Public? 2. Emergency Officials? 3. Local Public Officials? 4. Excavators? Municipalities, Schools Districts , Businesses, and 5. Residents?
How important is this to you and your community?
Roanoke, Alabama May 2016 Coordinated with first responders and city school board Held emergency drill based on report of natural gas leak Had all students evacuated and accounted for in 8 minutes Prior Planning: Mapping of all gas in area of schools Staging areas for students and staff designated away from gas lines Staging areas for first responders designated to limit traffic and allow access for emergency vehicles
For additional information, contact Brent Wilson Roanoke Utilities Board (334) 863 ‐ 4055 (6)
Construction Inspection Issues Gash in pipe about to be covered up
Tracer wire wrapped around pipe
Dragging pipe on asphalt/rocks
Additional Construction Issues Lack of certification for plastic fusion Lack of procedures on job site Lack of qualified inspector on job site Dirty/non ‐ functioning tools being used for fusion Not checking temperature with a pyrometer ‐ relying on temperature gauge on fusion iron
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