Pipeline Saf

COGCC Staff Pres

COLORAD

Public Utili

Commissi

Who Regulates Pip

July 17, 2013
Pipeline Safety Certificat

Under state statute, the Colorado Public Utilities Commiss(PUC) Gas Pipeline Safety section is charged with enforcethe state’s intrastate gas pipeline safety regulations.These statutes allow the Commission to enter into cooperaagreements with the Federal Pipeline and Hazardous MateSafety Administration (PHMSA). The Certification Agreebetween the PUC and PHMSA provides the structure arouthe state pipeline safety activities occur.PHMSA continues to regulate the safety of Inter/IntrastatHazardous Liquids and interstate natural gas pipelines in C

2013 O&G Permit/Seismic Ac
Focus on Pipeline Segment 

(Risk = probability X consequence
Colorado Springs Are

Black Forest(L), Waldo Canyon
Distribution

Westminster, CO

June 13, 2013
Transmission
Common Realities of the Pipeline 
Integrity Management (

Know your system threats and rank 
Material threats: Cast Iron Mile

Comparison

Top 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, Peoples 

Gas Light&Coke, Niagara Mohawk Power, PhilidelphiaGas Works , DTE Gas, Boston Gas, Keyspan, ConEd,...

Western Region CI St

 California (102 mi.) Colorado (34 mi.) Washington (7 mi.) Gas Utilities: PG&E

Energy, Puget Soun
Midstream (Gathering) Segm

Rulemaking Background

 History

 1968 & 1979 Fed. Statutory Exclusions for Rural Gas Gathering Inside city limits regulated – original assumption was this was an area 

population density

 1992 Gathering Line Federal Mandates (Fed. PSA 1992 & 1996) Not all cities had high population density. Safety goal : protect the pu

re-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 C

rulemaking

 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 
Midstream Segment Tod

 Current Requirements – what have w

learned 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 Consequence
How We Establish What We Reg

 Transportation – CPUC defined Production (flow lines) – CPUC defined Gathering (transportation pipeline)-PHMSA 

defined and adopted

 Transmission (transportation pipeline)-PHM

defined and adopted

 Distribution (transportation pipeline)-PHM

defined as main and service lines and adop
Definitions

 "Transportation of gas" means the gathe

transmission, distribution, or storage of gas the State of Colorado that is not subject to tjurisdiction of the Federal Energy RegulatoCommission under the Natural Gas Act.

 “Production” – by defn. no transportation 
CPUC Definitions

 "Production facility" means flowline and associate

equipment used at a wellsite in producing, extractin

recovering, lifting, stabilizing, initial separating and/initial dehydrating, disposal, and above ground storiliquid hydrocarbons, associated liquids, and associathydrocarbon gases. A production facility may incluflowlines up to a central delivery point directly ass

with a specific producing field. To be a production under this definition, a flowline must be used in the extracting hydrocarbons and associated liquids from ground or from facilities where hydrocarbons are promust be used for disposal or injection in reservoir mor recovery operations.
End Point of Productio
Possible Central Delivery P

and End Point of Produc
Definitions

"Transmission pipeline" means a pipeline, other thgathering pipeline or distribution pipeline, that does ofollowing: (I) Transports gas from a gathering pipeline or storage fac

distribution center, or storage facility.

 (II) Operates at a hoop stress of 20 percent or more of SMY (III) Transports gas within a storage field. (IV) Is a direct sales pipeline serving a large volume custom

downstream of a distribution center, which may include, but limited to, factories and power plants.
Definitions

 "Gathering Line" means a pipeline that transpor

a current production facility to a transmission line 

 "Main" means a distribution line that serves, or is 

to serve, as a common source of supply for more tservice line

 “Service line” means a distribution line that trans

or is designed to transport gas, from a common sosupply to an individual customer...
Gathering-inside and outs

“fields”

Bubba GumpCompressor Station*

MamaCompressor Statio

Field

Field

Field

Field

12" (or 16")

12"

12"

8"

8"

BV

BV

BV

Chocolate BoxCompressor Station*

LT DanCompressor Station*

JennySt(dehy & 

12" (or 16")

Field
Definition Problems

 In-Field compressors-reduce back pressure on pro

wells - production or gathering? Who owns comprproducer or midstream operator ?

 If no in-field compression required-downstream 

compression reduces back pressure on producing wproduction or gathering? Who owns compressor-pgathering operator?

 Define Compression: <1000 HP, skid mounted vs

>1000 HP, .... 
End of Gathering
Possible Prescriptive 

Restrictions on State Defin

Separation, dehydration equipment used to safeguard the operation of gatherincompressors. Under a possible limitation, aequipment being used to protect a gathering compressor would not be part of production operations and/or end point of production. Scrubbers, outside of storage fields, can alsdelineating end point for production and /ogathering.
Possible Prescriptive 

Restrictions on State Defin

 Natural gas processing plant is a natural gas 

processing operation, other than production proceoperated for the purpose of commercially extractingas liquids from the gas stream. Cryogenic equipmbe involved. Total volume liquid on-site storage mfactor – PSM plant. 

 Use first plant as endpoint of gathering and begin

transmission - depends on incoming production doand if token well, no definition of production proc
Plants - Process Safety Manage

(PSM = OSHA)
Possible Prescriptive 

Restrictions on State Defin

 Gas treatment (other than treatment in g

processing or compression) as involving sistand-alone facilities (e.g., a sulfur recover

extraction-amine tower, or large dehydratiofacility). Total volume liquid storage may b

Note: PHMSA rulemaking will place CO

2 pip

(gaseous state) under Hazardous Liquid Piperegulations (49 CFR, Part 195). 
Possible Prescriptive 

Restrictions on State Defin

 Gathering line gas treatment facility 

a series of gas treatment operations, other tproduction treatment, operated for the purpremoving impurities (e.g., water, solids, basediment and water, sulfur compounds, cardioxide(amine tower), etc.) not intended to simple piece of equipment like a separator dehydrator.” 

 No definition of production treatment 
Gathering System Catego

Type “A” High pressure steel pipelines

(Hoop stress of > 20% SMYS

* or > 125 psig if non

Type “B” Lower pressure steel pipelines

(Hoop stress of < 20% SMYS or < 125 psig for non

Type “C” all pressures, all materials

All other gathering pipelines outside of Class 2, 3, 

NOTE: Possible “incidental gathering” may be considered in future rulemaking w/ operator waiver/plan.* SMYS = specified minimum yield strength for steel pipe 
Class Location Definition

t The class location unit is an area that extends 220 yar

either side of the centerline of any continuous 1-mile 

pipeline.

The class location is determined by the number of buil

the class location unit. For the purposes of this sectio

separate dwelling unit in a multiple dwelling building counted as a separate building intended for human occupancy.
How Do We focus on Population Den

t Class 1 : < 10 buildings intended for human 

occupancy.

t Class 2 : 10 to 46 buildings intended for 

human occupancy.

t Class 3 : > 46 buildings intended for huma

occupancy; or
Class Location Unit

Class 3 - where the pipeline lies within 100 yards of e

building or a small:

t Well-defined Outside Area 

 Playground Recreation Area Outdoor Theater 

t Occupied by 20 or more 

persons on at least 5 days a week for 10 weeks in any 12-month period
Class Location Unit

Class 4 - where buildings

with four or more stories aboveground are prevalent.
Regulated gathering segm

 Type “A” High pressure pipeline-operators 

house count / “well defined outside area” sand perform class 2, 3, 4 determination me

 Type “B” lower pressure pipelines-operato

perform house count / “well defined outsidsurvey and perform class 2, 3, 4 determinamethod or using 150’ window sliding mile 

dwellings, or using 150’ window sliding 105 dwellings)
What Segment is Regula

( Type B, Area 2(c))

Segment A

1000 Feet

Segment B

1000 Feet

Segment C

1000 Feet

Total Regulated Pipeline Segment

150 Feet

150 Feet

150 feet

150 feet
CPUC Requirement

 Type “A” Gathering

 All natural gas transmission line activiti

required by the Federal Pipeline Safety Regulations (49 CFR Part 192-Natural G

Note: Liquids gathering is covered by 49 C195-Hazardous Liquids.
Minimum CPUC Requirem

 Type “B” Gathering in class 2, 3, 4 areas

 After 2006 all new, replaced, relocated, modified pipelines : al

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 (additiona Prepare a written Procedural Manual (additional requirement)

NOTE: Possibility of adding 192.613 to ensure class location upd
CPUC Requirements

Type “C” Gathering (all rural - class 1 areas) a) Gathering pipeline operating at a hoop stress > 20% SMYS 

metallic pipeline operating > 125 psig and located in a Class shall telephonically report any incident, or events as described 4911(b) to Staff. Any hazardous leakage or conditions which to a safety threat to the public shall be promptly repaired and documented;

 b) Tier 1 Member at the Colorado 811 (Utility Notification C

Colorado-UNCC) created under C.R.S. Section 9-5.5-105; an

 c) Install and maintain pipeline markers at each crossing of a 

and railroad
CPUC Telephonic Reporting Requiremen

Applicable to all Intrastate Pipelines

Any “incident” or “event” on any “pipeline”, Liquified NMaster Metered or Propane System. This includes Type gathering.“Events” included: gas leak resulting in the closure of a 

roadway, or Evacuation of > 50 people from a norma

building or property. 

“Incident”: gas release resulting in death, injury requirinstay at hospital, unintentional gas loss of three million cumore, property damage > $50,000
What Is Next?

 PHMSA gas gathering rule making early 

2014 - possible results: 

 Drop class locations Regulate all > 8-5/8 high pressure gas gathering High pressure means can operate at a hoop stress > 20% SM Gathering starts at the well site (on-site lease measurement) Additional reporting requirements CPUC to adopt in a normal rulemaking process w/ the addit

192.613 Continuing Surveillance.

 Consider Class 1 “incidental gathering” as Type “B” gatheriNOTE: Low stress liquid pipelines / crude gathering lines are Pjurisdictional – see 49 CFR Part 195. PHMSA Rulemaking pla