4/13/2020
2020 Pipeline Safety Conference
April 14, 2020
JON WOLFGRAM, CHIEF ENGINEER – MINNESOTA OFFICE OF PIPELINE SAFETY
OUR GOALS FOR TODAY!
• Stay connected!
• Stay focused!
• Talk processes!
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OUR AGENDA FOR TODAY
• MNOPS Update
• 2020 Inspections
• COVID-19
• Minnehaha Academy Incident
• Silver Springs Maryland Incident
• Your Questions.
MNOPS
• 19 Staff Total
• 14 Inspectors
• (3) Field Offices
• Pipeline Safety Inspection & Investigations
• Damage Prevention Education and
Enforcement
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SINCE THE LAST TIME:
LOTS OF INSPECTIONS
CENTURYLINK LOCATE ISSUES
NEW DIRECTOR – JIM SMITH
MS216D MEETINGS
(2) INSPECTOR OPENINGS
COVID-19
2019 INSPECTION PERSON DAYS
Inspection Types Natural Gas Hazardous Liquid
Grand Total
Standard Inspections 495 82 578
Design and Construction 295 3 298
Operator Training 13 0 13
Integrity Management 36 5 41
Operator Qualification 27 1 29
Accident/Incident Investigation 141 13 155
Damage Prevention Inspection and Investigations
120 6 126
Compliance Follow up 60 5 65
Grand Total 1187 116 1304
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Total Incidents 2009‐2019 (National)
0
100
200
300
400
500
600
700
800
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Total Incidents 2010‐2019 (MN)
0
2
4
6
8
10
12
14
16
18
20
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
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Total Incidents By Cause 2010‐2019 (National)
ALL OTHER CAUSES 4%
CORROSION 16%
NATURAL FORCE DAMAGE 6%
OTHER OUTSIDE FORCE DAMAGE 8%
EXCAVATION DAMAGE 10%
INCORRECT OPERATION 12%
MATERIAL/WELD/EQUIP FAILURE 44%
Incidents By Cause 2010‐2018 (MN) ALL OTHER CAUSES
3%
CORROSION 5%
EXCAVATION DAMAGE 8%
INCORRECT OPERATION 17%
MATERIAL/WELD/EQUIP FAILURE 41%
NATURAL FORCE DAMAGE 20%
OTHER OUTSIDE FORCE DAMAGE 6%
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Total Incidents By Cause 2010‐2019 (MN)
0
1
2
3
4
5
6
7
8
9
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
ALL OTHER CAUSES CORROSION EXCAVATION DAMAGE INCORRECT OPERATION
MATERIAL/WELD/EQUIP FAILURE NATURAL FORCE DAMAGE OTHER OUTSIDE FORCE DAMAGE
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INSPECTIONS: 2019
(116) Pipeline Safety Issues Cited
Top 5
1. 192.605(a) – O&M – Procedures & Review
2. 191.11- Distribution Annual Reports
3. 192.605(b)(8) – O&M – Effectiveness Review for Procedures
4. 192.1007(a)(2) – DIMP Knowledge: Info. from design, ops and maintenance
5. 192.1007(a)(3) – DIMP Knowledge: Identification of needed information.
DAMAGE PREVENTION: 2019
(193) Damage Prevention Safety Issues Cited
Top 5
1. Not located by start time on ticket / mis-locate.
2. No ticket.
3. Failure to notify of no marks by start time.
4. Failure to find precise location of facility.
5. Failure to maintain clearance with equipment.
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2019 Annual Report
Looking ahead!
1. Work together through challenges!
2. Complete 2020 inspections.
3. Operator RSI
4. Continue to refine the new MNOPS Database.
5. Work to build an operator portal.
6. Hire new staff.
7. Get back to normal!!
https://dps.mn.gov/divisions/ops/about/Pages/default.aspx
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Operator RSI
Due July 1, 2020 https://www.cognitoforms.com/MNOPS1/MNOPSRSIAllOperators
1. Request for Plans and Procedures
2. PHMSA Advisory Bulletins
3. NTSB Recommendations
4. Low Pressure Distribution Systems
5. Pipeline Safety Management Systems
6. Environmentally Sensitive Areas
Statute Changes
1. MS216D
2. Pipeline Civil Penalty Amounts
3. Continue to provide feedback
4. Legislature Focus – COVID19
5. Back in session Today.
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2020 Inspections
1. Inspections as planned for 2020
2. Aim for “Virtual” Inspections
3. Inspectors will “Prep” by reviewing plans
4. Solo Field Inspections
5. Construction Inspections – Social Distancing
6. Investigations – Social Distancing
Stay-of-Enforcement & Waivers
PHMSA Stay – OQ, D&A, & CRM
MNOPS will consider for intrastate upon request
Notify MNOPS of potential Issues
MNOPS will respond in writing
Items outside of the PHMSA Stay will require a waiver
Reference 190.341 & Minnesota Statute 299F.57 Subdivision 5.
https://www.phmsa.dot.gov/news/phmsa‐stay‐enforcement‐covid‐19
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NTSB Recommendations:
SILVER SPRINGS, MARYLAND INCIDENT
INFORMATION PROVIDED BY PHMSA
https://www.ntsb.gov/investigations/AccidentReports/Pages/par1901.aspx
Silver Springs, Maryland Incident
An explosion and fire occurred on August 10,2016 at an apartment complex.
14 units in the apartment building partially collapsed.
7 residents died
65 resident were transported to the hospital
3 firefighters were transported and released from the hospital
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Incident Cause
The failure of an indoor mercury service regulator with an unconnected vent line that allowed natural gas into the meter room where it accumulated and ignited from an unknown ignition source.
Incident Cause
The actual photo of the unthreaded union:
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NTSB Recommendations:
Require that all new service regulators be installed outside occupied structures. (P‐19‐001)
Require existing interior service regulators be relocated outside occupied structures whenever the gas service line, meter, or regulator is replaced. In addition, multifamily structures should be prioritized over single‐family dwellings. (P‐19‐002)
192 Enforcement Implications:
Subpart H – Customer Meters, Service Regulators, and Service Lines (192.353, 192.355, 192.357, etc.)
Requirements for Corrosion Control (192.481)
Subpart L – Operations (192.615)
Subpart M – Maintenance (192.723)
Subpart P – Distribution Integrity Management Plan (DIMP)
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DIMP
192.1007(a) – Knowledge: Do you know the location, type, maintenance, and leak call history of ALL your system’s inside meter sets? Can you demonstrate this to an inspector?
192.1007(b) – Identify Threats: “An operator must consider reasonably available information to identify existing and potential threats. Sources of data may include, but are not limited to, incident and leak history, corrosion control records, continuing surveillance records, patrolling records, maintenance history…”
NRC 1155909 (Silver Springs) has put the entire gas distribution industry on notice with respect to indoor meter sets as a system integrity risk.
DIMP
192.1007(d) – Identify and Implement Measures to Address Risks:
1. Address the possible need for specific measures to address sub‐categories of inside meter set risks, e.g., meter types, multi‐unit buildings, special venting issues, etc.
2. Special/Accelerated AC & Continuing Surveillance Patrols Vent testing/Replacement/Move out Programs
3. “Red tag” and shut‐in as an explicitly considered option to remove risk
4. Others?
192.1007(f) – Periodic Evaluation and Improvement: “An operator must re‐evaluate threats and risks…”. If you haven’t re‐evaluated your DIM program with respect to Silver Springs and other incidents – Why Not?
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Inside Regulator Considerations: 192.199
(e) Have discharge stacks, vents, or outlet ports designed to prevent accumulation of water, ice, or snow, located where gas can be discharged into the atmosphere without undue hazard;
(f) Be designed and installed so that the size of the openings, pipe, and fittings located between the system to be protected and the pressure relieving device, and the size of the vent line, are adequate to prevent hammering of the valve and to prevent impairment of relief capacity;
Inside Regulator Considerations: 192.355 (b)
(b) Requiring service regulators to terminate outdoors
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Inside Regulator Considerations: 192.355 (b)(1)
(b)(1) Must be rain and insect resistant
Inside Regulator Considerations: 192.355 (b)(2)
(b)(2) Be located at a place where gas from the vent can escape freely into the atmosphere and away from any opening into the building
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Inside Regulator Considerations: 192.355 (b)(2)
Inside Regulator Considerations:
Recommendation: Install service regulators away from an ignition source
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Inside Regulator Considerations: 192.357 (d)
Requires regulators that might release gas to be vented to the outside atmosphere
Inside Regulator Considerations: 192.353(a)(b)(c)
• Requires each service regulator to be located in a readily accessible location, and that if service regulators are installed in a building they must be located as near as practical to the service line entrance to the building.
• Gas service regulators must be installed in readily accessible location.
• Each meter installed within a building must be located in a ventilated place.
• Inside meter must be not less than 3 feet from any source of ignition.
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Inside Regulator Considerations: 192.723
• The following leakage surveys are required for inside and outside piping up to the outlet of the gas meter.
• Business districts at intervals not exceeding 15 months, but at least once each calendar year.
• Outside business districts as frequently as necessary, but at least once every five calendar years at intervals not exceeding 63 months for plastic and cathodically protected lines; cathodically unprotected distribution lines every 3 calendar years at intervals not exceeding 39 months.
Inside Regulator Considerations: 192.481
• Perform Every 3 years, Not To Exceed 39 months for inside and outside piping up to the outlet of the meter.
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Inside Regulator Considerations:
Ensure vent line is not corroded:
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Ensure vent line is properly sized:
Ensure vent line is properly sized:
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Additional Considerations:
Vents must use metallic pipe, not PVC
PVC can create static electricity
Metallic piping will create structural integrity
Perform Visual Inspection and Observations on inside piping.
Make sure all piping is connected
The best practice is to relocate service regulators and gas meters outside.
Minnehaha Academy Explosion
https://www.ntsb.gov/investigations/AccidentReports/Pages/PAB1903.aspx
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Minnehaha Academy Explosion
August 2, 2017
Building Explosion
(2) Fatalities
(9) Injuries
Meter-move-out work
Mechanical Contractor working on Jurisdictional Piping
Valve open
LOCKOUT-TAG-OUT
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Minnehaha Academy Explosion: Takeaways
Ensure only qualified personnel work on your system.
Awareness to Mechanical Contractors regarding.
jurisdictional components.
Ensure proper purging of all piping.
Perform pre-project walk-troughs and design reviews.
Identify all required valves and ensure they work.
MNOPS Alert Notice February 2, 2018
Incidents Can Share Similarities:
Review work prior to starting it.
Look for the loose ends in the field or in procedures.
Ensure adherence to procedures.
Don’t make assumptions.
Identify shut-down plans prior to beginning work.
Find the valves you might need.
Find a backup valve.
Make sure they work.
Does LOTO (Lock out / Tag out) apply?
https://www.osha.gov/SLTC/controlhazardousenergy/
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Questions?
THANK YOU!
PIPELINE SAFETY TAKES ALL OF US!
THANK YOU FOR WHAT YOU DO!
STAY SAFE!
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