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OPS Official Wants to Beat Congress to the Punch in Improving Distribution Line Safety

The Department of Transportation's Office of Pipeline Safety (OPS), in concert with state regulators, would like to "get there first before Congress" with "some sort of guidance document" or a "simple federal regulation" aimed at increasing the safety record of natural gas distribution pipelines, said OPS Associate Administrator Stacey Gerard last Tuesday.

The DOT's inspector general (IG) "has stirred up a lot of enthusiasm in the Congress" to apply the kind of prescriptive integrity management rules that have been implemented for gas transmission pipelines to the distribution side, she said during a winter meeting of the National Association of Regulatory Utility Commissioners (NARUC) in Washington, DC. The IG appears to believe that if integrity management rules are "good for the goose [transmission], how about the gander," she noted.

"It seems to be a bread and butter, Mom and...apple pie [issue] in the Congress these days," she told state regulatory commissioners. "I think that there may be real interest in kind of bagging a few new provisions" that deal with the safety of distribution pipelines in the Pipeline Safety Act that is scheduled for reauthorization in 2006, Gerard said.

Congress is insisting that OPS provide an update of what it is doing to improve the safety of distribution pipelines. Given that the White House and Office of Management and Budget must pre-approve whatever it submits, she said OPS needs to come up with "some sort of plan, just a plan, in the March time frame." Gerard urged the gas pipeline industry not to waste time in providing input.

It could be a "simple blueprint." Or at the end of the day, Gerard believes that state regulators could find acceptable a "simple federal regulation," which would give state commissioners the flexibility to take action. "What would the characteristics be of an [integrity management] regulation if there was a federal regulation? I think that it would be something that would be very simple and clear by its design," she said.

An example would be a regulation requiring operators to have an integrity plan that reflects 1) knowledge of the infrastructure; 2) consideration of applicable threats; 3) activities to reduce risks; 4) and a process for monitoring performance.

A steering team comprised of state regulators, industry/trade executives, the public, OPS officials and state fire marshals "has to inform [the] process," she said. "I think it's really important to identify what are the questions we need to answer in a year. I don't want this team to have to feel that [it has] to solve world hunger in a year. Let's just break off some bite-size pieces of the questions that we could answer so that when the Congress tracks what we're doing, they'll say, 'There's a good thing going on here. Legislation isn't necessary.' Or if they feel compelled to have a provision in [the Pipeline Safety Act], it will mirror what comes out of this team."

Gerard endorsed the NARUC Committee on Gas's approval of a resolution last week in support of integrity management rules for distribution pipelines.

On a related issue, she noted that the National Transportation Safety Board (NTSB) has recommended that the OPS implement a federal mandatory requirement for excess flow valves (EFV), which are used to cut off natural gas service in the event of a rupture on a distribution pipeline.

Gerard called on state commissioners to tackle the issue at the state level. She noted that the "NTSB would feel assured that state regulators were providing some sort of backstop."

The National Fire Protection Association favors a requirement for EFVs, noting that it costs a utility only $5 to $10 to install an EFV. "I just don't think it's going to play well not to have the requirement" for EFVs, Gerard said.

In a preview of an upcoming report, the American Gas Foundation (AGF) found that while more than one-third of all gas distribution accidents between 1990 and 2002 could be classified as serious, there has been a marked decrease in the number of serious incidents over the years.

Of a total of 1,579 reported incidents on gas distribution lines during the 12-year period, the AGF said 601, or 38%, were serious. However, it said serious incidents showed a downward trend of approximately 40%. In 1994, nearly four incidents were reported per 100,000 miles of distribution lines, but that figure fell to two per 100,000 miles of distribution lines in 2002.

Serious incidents and fatalities/injuries on distribution lines outpaced those on transmission pipelines, AGF reported. Serious incidents on distribution lines were 2.8 per 100,000 miles versus 2.4 per 100,000 miles for transmission lines over the period, while distribution fatalities/injuries were 5.2 per 100,000 miles versus 4.2 per 100,000 miles for transmission facilities.

Gary W. Gardner of the American Gas Association (AGA) gave a preview of the study's conclusions at the NARUC winter meeting last Tuesday. The final report is expected to be issued soon, an AGA spokeswoman said.

Outside force damage was listed as the leading cause of serious incidents on distribution lines, according to the report's findings. Of the 601 serious incidents over the 12-year period, the AGF report said 280 incidents, or approximately 47%, were caused by outside force damage. Nearly 75% of the outside force damage was the result of third-party digging

The top five processes identified as having the highest impact on distribution line integrity were cathodic protection systems, leak surveys, operator qualification programs, one-call systems and planned pipe replacement programs, AGF said.

Threats to distribution line integrity were cited as external corrosion, internal corrosion, manufacture-related defects, construction-related defects, equipment malfunction, excavation/mechanical damage, incorrect operations and operator error, and outside force/weather.

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