Features
Safer gas distribution a must
by John A. Jacobi, PE
Community Assistance/Technical Services Manager
PHMSA Southwest Region
The largest segment of the nation’s pipeline network is the distribution systems that directly serve homes, schools, businesses, and other natural gas consumers. There are more than two million miles of distribution pipeline in the U.S., and more is being added every day. Most distribution lines are in highly populated areas and relatively shallow. It is not surprising that distribution lines are frequently damaged, and people are sometimes injured or killed as a result. Section 9 of the Pipeline Integrity, Protection, Enforcement and Safety Act of 2006 (PIPES) requires DOT to issue regulations requiring operators to focus on risks associated with the distribution of natural gas.
Although PIPES requires regulation, DOT has been working on distribution issues since at least 2004. See docket No.PHMSA-RSPA-2004-19854 found at www.regulations.gov, a wonderful resource for information regarding ALL Federal regulations. There are over 250 entries in the docket, including numerous public meetings, public comments and of course, the Notice of Proposed Rulemaking dated June 25, 2008 (NOPR). The final rule is pending and expected out late this summer, so the matter is ex parte; (i.e., I cannot discuss the details of the “final” version but I can discuss the generalities).
Here we go with the basic features:
- Risk-based written program including the seven elements
- Appropriate mitigation measures, including leak management and enhanced damage prevention
- Installation of Excess Flow Valves (EFVs)
- High-level, performance-based requirements – guidance will be needed for implementation
- Limited requirements for Master Meter/LPG systems
The seven elements are:
- Know your system
- Identify threats (incident criteria)
- Analyze risk (evaluate & prioritize)
- Mitigate risk
- Performance Measures (monitor & evaluate)
- Review/revised (improve)
- Report Performance Measures (report on annual report)
Sounds simple, doesn’t it? The devil is, as they say, in the details. At this point, there appears to be a number of somewhat controversial issues. PIPES requires excess flow valves. The new rule will try to make sure they are installed where appropriate. There will be provisions for “small” operators. Documentation and recordkeeping will increase, especially in regard to plastic pipe and fittings. “Damage” will be defined. A grace period before the new rules take effect will be provided. Flexibility will be allowed, and guidance will be provided to both large and small operators.
Will distribution systems be safer and injuries and deaths be reduced as a result of this rule-making? In my opinion, absolutely no doubt. Will it take some time to make a difference? Certainly. Will it cost the consumer money in the form of increased cost of gas? It has to – but there was an economic analysis done; see the NOPR. How much is a human life worth?
For questions, answers and latest information on DIMP, please go to www.phmsa.dot.gov/pipeline. Click on Integrity Management Program, and then select DIMP. When the final rule comes out, please read it, and let DOT know what you think. We work hard to get it right, but we are human. Your opinions can make a real difference. Thanks for listening.
