Pipeline SafetyCOGCC Staff PresentationCOLORADOPublic UtilitiesCommissionWho Regulates Pipelines ?July 17, 2013Pipeline Safety CertificationUnder state statute, the Colorado Public Utilities Commission’s(PUC) Gas Pipeline Safety section is charged with enforcement ofthe state’s intrastate gas pipeline safety regulations.These statutes allow the Commission to enter into cooperativeagreements with the Federal Pipeline and Hazardous MaterialsSafety Administration (PHMSA). TheCertification Agreementbetween the PUC and PHMSA provides the structure around whichthe state pipeline safety activities occur.PHMSA continues to regulate the safety of Inter/IntrastateHazardous Liquids and interstate natural gas pipelines in Colorado.2013 O&G Permit/Seismic ActivityFocus on Pipeline Segment Risk(Risk = probability X consequence)Colorado Springs AreaBlack Forest(L), Waldo Canyon(R)DistributionWestminster, COJune 13, 2013TransmissionCommon Realities of the Pipeline WorldIntegrity Management (IM)Know your system threats and rank your riskMaterial threats: Cast Iron MileageComparisonTop CI States(w >3000 miles)New Jersey (5044 mi.)New York (4417 mi.)Massachusetts (3792 mi.)Pennsylvania (3221 mi.)Michigan (3101 mi.)Gas Utilities: PSE&G, PeoplesGas Light&Coke, NiagaraMohawk Power, PhilidelphiaGas Works , DTE Gas, BostonGas, Keyspan, ConEd,...Western Region CI StatesCalifornia (102 mi.)Colorado (34 mi.)Washington (7 mi.)Gas Utilities: PG&E, XcelEnergy, Puget Sound EnergyMidstream (Gathering) SegmentRulemaking BackgroundHistory1968 & 1979 Fed. Statutory Exclusions for Rural Gas GatheringInside city limits regulated – originalassumption was this was an area of highpopulation density1992 Gathering Line Federal Mandates (Fed. PSA 1992 & 1996)Not all cities had high population density. Safety goal : protect the public. Move tore-write the safety regs. pertaining to gathering2005 CPUC-COGCC DiscussionsIndustry develops Recommended Practice 80 (API RP-80)2006 & 2008 Final Federal Rules for Regulated Gathering Lines and COGCCrulemakingPHMSA adopts RP-80 with specific restrictionsCPUC rule adoption by reference + reporting requirementJan. 8, 2007 COGCC – CPUC Gathering Pipeline ResolutionCPUC rulemaking updates ~every two years (safety rule adoption by reference)Midstream Segment TodayCurrent Requirements – what have welearned in the last 6 years?CPUC definitionsAdditional requirements above PHMSAFocus on populated areas (Class 2, 3)Act on Incident and Event Reporting StatisticsRisk = Probability X ConsequenceHow We Establish What We RegulateTransportation – CPUC definedProduction (flow lines) – CPUC definedGathering (transportation pipeline)-PHMSAdefined and adoptedTransmission (transportation pipeline)-PHMSAdefined and adoptedDistribution (transportation pipeline)-PHMSAdefined as main and service lines and adopted.Definitions"Transportation of gas"means the gathering,transmission, distribution, orstorage of gas withinthe State of Colorado that is not subject to thejurisdiction of the Federal Energy RegulatoryCommission under the Natural Gas Act.“Production”– by defn. no transportation occursCPUC Definitions"Production facility"means flowline and associatedequipment usedat a wellsitein producing, extracting,recovering, lifting, stabilizing, initial separating and/or treating,initial dehydrating, disposal, and above ground storing ofliquid hydrocarbons, associated liquids, and associated naturalhydrocarbon gases. A production facility may includeflowlinesup to a central delivery pointdirectly associatedwith a specific producing field. To be a production facilityunder this definition, a flowline must be used in the process ofextracting hydrocarbons and associated liquids from theground or from facilities where hydrocarbons are produced ormust be used for disposal or injection in reservoir maintenanceor recovery operations.End Point of ProductionPossible Central Delivery Pointsand End Point of ProductionDefinitions"Transmission pipeline"means a pipeline, other than agathering pipeline or distribution pipeline, that does one of thefollowing:(I) Transports gas from a gathering pipeline or storage facility to adistribution center, or storage facility.(II) Operates at a hoop stress of 20 percent or more of SMYS.(III) Transports gas within a storage field.(IV) Is a direct sales pipeline serving a large volume customer notdownstream of a distribution center, which may include, but not belimited to, factories and power plants.Definitions"Gathering Line"means a pipeline that transports gas froma current production facility to a transmission line or main."Main"means a distribution line that serves, or is designedto serve, as a common source of supply for more than oneservice line“Service line”means a distribution line that transports gas,or is designed to transport gas, from a common source ofsupply to an individual customer...Gathering-inside and outside of“fields”Bubba GumpCompressor Station*MamaCompressor Station*FieldFieldFieldField12" (or 16")12"12"8"8"BVBVBVChocolate BoxCompressor Station*LT DanCompressor Station*JennyStation**(dehy & meter)12" (or 16")FieldDefinition ProblemsIn-Field compressors-reduce back pressure on producingwells - production or gathering? Who owns compressor –producer or midstream operator ?If no in-field compression required-downstreamcompression reduces back pressure on producing wells -production or gathering? Who owns compressor-producer orgathering operator?Define Compression: <1000 HP, skid mounted vs. fixed,>1000 HP, ....End of GatheringPossible PrescriptiveRestrictions on State DefinitionsSeparation, dehydration equipmentis oftenused to safeguard the operation of gatheringcompressors. Under a possible limitation, anyequipment being used to protect a gathering fieldcompressor would not be part of productionoperations and/or end point of production.Scrubbers, outside of storage fields, can also be adelineating end point for production and /orgathering.Possible PrescriptiveRestrictions on State DefinitionsNatural gas processing plantis a natural gasprocessing operation, other than production processing,operated for the purpose of commercially extracting naturalgas liquids from the gas stream. Cryogenic equipment maybe involved. Total volume liquid on-site storage may befactor – PSM plant.Usefirst plantas endpoint of gathering and beginning oftransmission - depends on incoming production downstreamand if token well, no definition ofproduction processing.Plants - Process Safety Management(PSM = OSHA)Possible PrescriptiveRestrictions on State DefinitionsGas treatment(other than treatment in gasprocessing or compression) as involvingsignificantstand-alone facilities(e.g., a sulfur recovery, CO2extraction-amine tower, or large dehydrationfacility). Total volume liquid storage may be factor.Note: PHMSA rulemaking will place CO2pipelines(gaseous state) under Hazardous Liquid Pipelineregulations (49 CFR, Part 195).Possible PrescriptiveRestrictions on State DefinitionsGathering line gas treatment facilityis one ora series of gas treatment operations, other thanproduction treatment, operated for the purpose ofremoving impurities (e.g., water, solids, basicsediment and water, sulfur compounds, carbondioxide(amine tower), etc.) not intended to be asimple piece of equipment like a separator ordehydrator.”No definition ofproduction treatmentGathering System CategoriesType “A” High pressure steel pipelines(Hoop stress of > 20% SMYS*or > 125 psig if non-metallic)Type “B” Lower pressure steel pipelines(Hoop stress of < 20% SMYS or < 125 psig for non-metallic)Type “C” all pressures, all materialsAll other gathering pipelines outside of Class 2, 3, 4 locations.NOTE: Possible “incidental gathering” may be considered as Type “B”in future rulemaking w/ operator waiver/plan.* SMYS = specified minimum yield strength for steel pipe specificationClass Location DefinitiontTheclass location unitis an area that extends 220 yards oneither side of the centerline of anycontinuous1-mile length ofpipeline.The class location is determinedby the number of buildings intheclass location unit. For the purposes of this section, eachseparate dwelling unit in a multiple dwelling building iscounted as a separate building intended for humanoccupancy.How Do We focus on Population Density?tClass 1 :< 10 buildings intended for humanoccupancy.tClass 2: 10 to 46 buildings intended forhuman occupancy.tClass 3: > 46 buildings intended for humanoccupancy; orClass Location UnitClass 3- where the pipeline lies within 100 yards of either abuilding or a small:tWell-defined Outside AreaPlaygroundRecreation AreaOutdoor TheatertOccupied by 20 or morepersons on at least 5 days aweek for 10 weeks in any12-month periodClass Location UnitClass 4- where buildingswith four or more storiesaboveground are prevalent.Regulated gathering segmentsType “A” High pressure pipeline-operators performhouse count / “well defined outside area” surveyand perform class 2, 3, 4 determination methodType “B” lower pressure pipelines-operatorsperform house count / “well defined outside area”survey and perform class 2, 3, 4 determinationmethod or using 150’ window sliding mile w/ 10-46dwellings, or using 150’ window sliding 1000’ w/ >5 dwellings)What Segment is Regulated( Type B, Area 2(c))Segment A1000 FeetSegment B1000 FeetSegment C1000 FeetTotal Regulated Pipeline Segment150 Feet150 Feet150 feet150 feetCPUC RequirementType “A” GatheringAll natural gas transmission line activities asrequired by the Federal Pipeline SafetyRegulations (49 CFR Part 192-Natural Gas).Note: Liquids gathering is covered by 49 CFR Part195-Hazardous Liquids.Minimum CPUC RequirementsType “B” Gathering in class 2, 3, 4 areasAfter 2006 all new, replaced, relocated, modified pipelines : all design,installation, construction, inspection and testing reqts.;Carry out a damage prevention program;If the pipeline is metallic, control corrosion;Establish the maximum allowable operating pressure (MAOP);Install and maintain line markers;Establish a public awareness programInstrument leak survey (additional requirement)Reporting of “incidents” and “Events”to the CPUC (additional requirement)Prepare a written Procedural Manual (additional requirement)NOTE: Possibility of adding 192.613 to ensure class location updatesCPUC RequirementsType “C” Gathering (all rural - class 1 areas)a) Gathering pipeline operating at a hoop stress> 20% SMYS or nonmetallic pipeline operating > 125 psigand located in a Class 1 locationshall telephonically report any incident, or events as described in Rule4911(b) to Staff. Any hazardous leakage or conditions which may leadtoa safety threat to the publicshall be promptly repaired anddocumented;b) Tier 1 Member at the Colorado 811 (Utility Notification Center ofColorado-UNCC) created under C.R.S. Section 9-5.5-105; andc) Install and maintain pipeline markers at each crossing of a public roadand railroadCPUC Telephonic Reporting RequirementsApplicable to all Intrastate PipelinesAny “incident” or “event” on any “pipeline”, Liquified Natural Gas,Master Metered or Propane System. This includes Type A, B, C gasgathering.“Events”included: gas leak resulting in the closure of a railroad orroadway, or Evacuation of > 50 people from a normally occupiedbuilding or property.“Incident”: gas release resulting in death, injury requiring overnightstay at hospital, unintentional gas loss of three million cubic feet ormore, property damage > $50,000What Is Next?PHMSA gas gathering rule making early spring2014 - possible results:Drop class locationsRegulate all > 8-5/8 high pressure gas gatheringHigh pressure means can operate at a hoop stress > 20% SMYSGathering starts at the well site (on-site lease measurement)Additional reporting requirementsCPUC to adopt in a normal rulemaking process w/ the addition of192.613 Continuing Surveillance.Consider Class 1 “incidental gathering” as Type “B” gatheringNOTE: Low stress liquid pipelines / crude gathering lines are PHMSAjurisdictional – see 49 CFR Part 195. PHMSA Rulemaking plans???