Gas Pipeline Safety Leak Management Programs Pete Chace GPS Program Manager (614) 644-8983 Peter.chace@puc.state.oh.us
Recent proposed changes to the Ohio Administrative Code - Update Requires a follow-up inspection of repairs made to Grade 1 leaks. AGA GPTC Guidance: Where there is residual gas in the ground after repair of a Grade 1 leak, a follow-up inspection should be made as soon as practical after allowing the soil atmosphere to vent and stabilize, but in no case later than one month following the repair.
Recent proposed changes to the Ohio Administrative Code - Update Requires hazardous leaks to be evaluated (graded) using an instrument capable of detecting the concentration of gas in air. Only applies to grading hazardous leaks. Construction reporting dollar amount for reporting going up from $200,000 to $500,000. Disconnecting inactive services removed.
What is a Leak Management Program? Criteria for the detection, grading, and control of gas leakage and related records. Required by the Ohio Administrative Code. Maintaining a good leak management program helps keep customers happy. Accurate records help with DIMP program. Staff recommends the GPTC Gas Leakage Control Guidelines for leak management guidance.
An effective Leak Management program includes the following elements: Locate the leaks in the distribution system Evaluate the actual or potential hazards associated with these leaks Act appropriately to mitigate these hazards Keep records Self-assess to determine if leak management program is effective
Locate the leaks in the distribution system Follow Pipeline Safety Regulation time frames for leak surveys. Operator Qualification requirements apply: Surface gas detection Subsurface gas detection (including barholing) Vegetation survey Pressure drop test Bubble leakage survey
Locate the leaks in the distribution system Operators must know what leak detection instruments are and are not appropriate for the following: Leakage survey Leak investigation (first response) Leak classification (barholing) Pinpointing
Evaluate actual or potential hazards associated with leaks Leak grading criteria defined in the Ohio Administrative Code. Operator procedures must clearly define criteria for classifying a leak as hazardous, and OQ program must train employees on these criteria. GPS investigators look for knowledge of procedures, awareness of potential for gas migration, use of appropriate instrumentation, awareness of LEL and properties of natural gas.
Act appropriately to mitigate hazards Operator procedures must clearly define actions to make safe a hazardous leak. There is no such thing as a temporary repair of a hazardous leak. Code allows temporary measures such as venting, non-permanent devices, etc. (a physical action ) but the operator cannot leave the scene until permanent repair is complete. Grade 1 leak repairs subject to re-inspection.
Keep records Leak records should reflect date and time discovered, time evaluated and by whom, date and time re-evaluated and repaired. Hand drawn map of leak location recommended. Provide enough information to support the conclusion that a leak is or is not hazardous (% gas or % LEL readings on the map) Records must contain enough information to support the Leak Cause classification
Official Leak Causes (for 7100 Annual Report, DIMP, etc.) Corrosion leak resulting from a hole in the pipe or other component that was caused by galvanic, bacterial, chemical, stray current, or other corrosive action. Further classify as External, Internal, Atmospheric.
Official Leak Causes Natural Forces leak resulting from earth movements, earthquakes, landslides, subsidence, lightning, heavy rains/floods, washouts, flotation, mudslide, scouring, temperature, frost heave, frozen components, high winds, or similar natural causes.
Official Leak Causes Excavation Damage leak resulting from damage caused by earth moving or other equipment, tools, or vehicles. Includes leaks from damage by the operator s personnel (1 st party) or subcontractors (2 nd party), or people not associated with the operator (3 rd party).
Official Leak Causes Other outside force damage Includes leaks caused by vehicular damage, fire or explosion, and deliberate or willful acts such as vandalism.
Official Leak Causes Material or Welds leak resulting from failure of original sound material from force applies during construction that caused a dent, gouge, excessive stress, or other defect that eventually resulted in a leak. Includes manufacturing defects in the pipe or component material, manufacturing weld or seam defects, faulty wrinkle bends, faulty field welds, and damage sustained in transportation.
Official Leak Causes Equipment leak resulting from malfunction of control/relief equipment including valves, regulators, or other instrumentation; stripped threads or broken pipe couplings or nipples, valves, or mechanical couplings; or seal failures or gaskets, O-rings, seal/pump packing, or similar leaks.
Official Leak Causes Incorrect Operation leak resulting from inadequate procedures or safety practices, or failure to follow correct procedures, or other operator error.
Official Leak Causes Other leak resulting from any other cause, such as exceeding the service life, not attributable to the above causes. If you have too many leaks in the Other category you either have a unique threat to your pipeline system that needs to be investigated or you re not doing it right.
Self-assess to determine if leak management program is effective Perform self audits, define metrics, and monitor trends such as: Scheduling leak surveys meeting time frames? Survey effectiveness consistent evaluation? Repair scheduling made within specified time? Repair effectiveness re-inspection of leaks? Leak records maintained as required?
Annual Report Data for Ohio
Annual Report Data for Ohio
Annual Report Data for Ohio
Mechanical Fitting Failure Reports 192.1009 - Operators must file a 7100.1-2 Mechanical Fitting Failure report for mechanical fitting failures that result in a hazardous leak. Hazardous Leak = Grade 1 Leak Mechanical Fitting applies only to: Stab Type fittings; Nut Follower Type fittings; Bolted Type fittings; Other Compression Type fittings.
Mechanical Fitting Failure Reports 192.1009 Reporting requirements do not apply to: Master Meter operators; Small LPG operators; LNG facilities. 191.12 describes reporting process: Electronic filing required (waiver provision); Operators may file throughout the year or submit all in a batch by March 15 th of the following year; See http://www.phmsa.dot.gov/pipeline/library/forms
Mechanical Fitting Failure Reports Report failures in the bodies of mechanical fittings, failures in the joints between the fitting and the pipe, and when the pipe pulls out of the fitting. Properly classify the Apparent Cause of the leak. PHMSA is trying to gather information on the cause of fitting failures to direct efforts towards future rulemaking, advisory bulletins, etc. Bad data = bad rules.
Mechanical Fitting Failure Report Data for Ohio
Mechanical Fitting Failure Report Data - Leak Location
Mechanical Fitting Failure Report Data Coupling Material
Mechanical Fitting Report Data Component
Mechanical Fitting Failure Report Data Type of Fitting
Questions? Pete Chace GPS Program Manager (614) 644-8983 Peter.chace@puc.state.oh.us