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From page 54... ... 54 This chapter reviews the safety regulatory framework for liquefied petroleum gas (LPG) pipeline distribution systems; the number, location, and size of the systems subject to the regulation; and the concerns raised by the LPG industry about the applicability, safety benefits, and compliance burden of federal regulations imposed on LPG systems serving 100 or fewer customers. Read the entire page →
From page 55... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 55 small jurisdictional systems are considered. The chapter concludes with a summary assessment of the issues raised by industry in light of what is known about these small pipeline systems and the safety benefits of the federal regulatory requirements in question. Read the entire page →
From page 56... ... 56 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS requirements. This support and guidance is intended in part to bring about a more consistent level of regulatory understanding and enforcement across states. Read the entire page →
From page 57... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 57 a place that is generally open to all persons in a community as opposed to being restricted to specific persons. Examples of public places include churches, schools, and commercial buildings, as well as any publicly owned right-of-way or property frequented by a person.6 In trying to determine how many LPG systems are jurisdictional, the committee learned that PHMSA's regulatory definition and guidance leave considerable room for interpretation. Read the entire page →
From page 58... ... 58 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS NAPSR Questionnaire Results State pipeline safety managers were asked by NAPSR to estimate the total number of LPG jurisdictional systems in the state, including the number serving 100 or more customers, 50 to 99 customers, 10 to 49 customers, and fewer than 10 customers. NAPSR sent the questionnaire to 50 states, the District of Columbia, and Puerto Rico. Read the entire page →
From page 59... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 59 TABLE 4-1 Number of Jurisdictional LPG Pipeline Distribution Systems of Different Size, Reported by 28 States That Provided Size Information, 2017 System Size, Customers Served Systems Percentage of Total Systems Reported Fewer than 10 1,672 49 10 to 49 1,239 37 50 to 99 206 6 100 or more 188 8 Total 3,305 100 SOURCE: National Association of Pipeline Safety Representatives, "Questionnaire to State Pipeline Safety Program Managers on the Regulation of Liquefied Petroleum Gas Distribution Systems," January 2018. Another possible explanation for the results in Table 4-2 is that some states are not trying, or are finding it difficult, to identify certain jurisdictional systems, particularly the very small ones with two to nine customers. Read the entire page →
From page 60... ... 60 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS TABLE 4-2 Smallest Systems as a Percentage of Jurisdictional LPG Pipeline Distribution Systems per State, Reported by 28 States That Provided Size Information, 2017 State Systems with 2–9 Customers Total Systems Systems with 2–9 Customers as Percentage of Total Systems Arizona 0 6 0 Arkansas 0 3 0 California 69 650 11 Colorado 0 7 0 Connecticut 247 352 70 Delaware 9 102 9 Iowa 0 2 0 Maine 511 623 82 Maryland 10 57 18 Massachusetts 3 11 27 Michigan 9 29 31 Minnesota 1 11 9 Montana 0 5 0 Nevada 5 15 33 New Hampshire 539 832 65 New Mexico 0 6 0 New York 1 4 25 Pennsylvania 0 15 0 Puerto Rico 14 31 45 South Carolina 0 3 0 Texas 11 76 14 Utah 0 34 0 Vermont 233 357 65 Virginia 10 68 15 West Virginia 0 1 0 Wyoming 0 1 0 Total 1,672 3,305 51 SOURCE: National Association of Pipeline Safety Representatives, "Questionnaire to State Pipeline Safety Program Managers on the Regulation of Liquefied Petroleum Gas Distribution Systems." Read the entire page →
From page 61... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 61 TABLE 4-3 Number of Jurisdictional LPG Pipeline Distribution Systems per State, Reported by 28 States That Provided Size Information, by System Size, 2017 State 2–9 Customers 10–99 Customers 100 or More Customers Total Arizona 0 1 5 6 Arkansas 0 3 0 3 California 69 516 65 650 Colorado 0 1 6 7 Connecticut 247 105 0 352 Delaware 9 48 45 102 Iowa 0 1 1 2 Maine 511 111 1 623 Maryland 10 36 11 57 Massachusetts 3 0 8 11 Michigan 9 18 2 29 Minnesota 1 6 4 11 Montana 0 2 3 5 Nevada 5 8 2 15 New Hampshire 539 292 1 832 New Mexico 0 6 0 6 New York 1 3 0 4 North Dakota 0 0 2 2 Ohio 0 0 2 2 Pennsylvania 0 10 5 15 Puerto Rico 14 16 1 31 South Carolina 0 3 0 3 Texas 11 45 20 76 Utah 0 34 0 34 Vermont 233 123 1 357 Virginia 10 56 2 68 West Virginia 0 0 1 1 Wyoming 0 1 0 1 Total 1,672 1,445 188 3,305 SOURCE: National Association of Pipeline Safety Representatives, "Questionnaire to State Pipeline Safety Program Managers on the Regulation of Liquefied Petroleum Gas Distribution Systems." Read the entire page →
From page 62... ... 62 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS Lower Atlantic regions where some states with larger jurisdictional systems report zero very small jurisdictional LPG systems and others report zero jurisdictional systems altogether. The system counts from the NAPSR survey, combined with the counts derived from NPGA estimates, provide some indication of the number of LPG systems that are jurisdictional. Read the entire page →
From page 63... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 63 TABLE 4-4 Jurisdictional LPG Systems Reported by 49 States and Puerto Rico to NAPSR by State Pipeline Safety Program Managers and by the NPGA, 2017 NAPSR NPGA Customers Served Systems Percentage, Total Systems Percentage, Total Fewer than 10 1,672 44 4,313a 75 10 to 49 1,239 33 50 to 99 206 5 1,150 20 100 or more 263 7 287 5 Fewer than 100, potentially all sizes 404b 11 Total 3,784 100 5,750 100 a NPGA reported this estimate for systems serving fewer than 50 customers. b Six of the 34 states with jurisdictional LPG systems reported their systems as small (fewer than 100 customers) Read the entire page →
From page 64... ... 64 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS tomers. Such requirement-by-requirement assessments are complicated by the fact that LPG systems with 100 or fewer customers are not uniform in their configurations, design features, and settings. Read the entire page →
From page 65... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 65 PHMSA has incorporated by reference the NFPA codes since 1970. According to Part 192, a jurisdictional system that transports LPG must meet the requirements of NFPA 58, Liquified Petroleum Gas Code (2004 edition) Read the entire page →
From page 66... ... 66 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS Box 4-1 NFPA 58, Liquefied Petroleum Gas Code (2004 Edition) , Summary of Content Chapter 1: Administration Chapter 2: Referenced Publications Chapter 3: Definitions Chapter 4: General Requirements (e.g., acceptance of equipment and sys tems, gas odorization, notification of installations) Read the entire page →
From page 67... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 67 Box 4-2 Major Provisions of Part 192 Regulations and Example Content Subpart A -- General §§ 192.1–192.16 Scope, definitions, class locations Subpart B -- Materials §§ 192.51–192.65 Steel pipe, plastic pipe, marking of material Subpart C -- Pipe Design §§ 192.101–192.125 Wall thickness, yield strength, temperature rating Subpart D -- Design of Pipeline Components §§ 192.141–192.203 Fittings, outlets, anchors, pressure limiting devices Subpart E -- Welding of Steel in Pipelines §§ 192.221–192.245 Procedures, welder qualifications, inspections and testing Subpart F -- Joining of Materials Other Than by Welding §§ 192.271–192.287 Iron, plastic, copper pipe, inspection Subpart G -- General Construction Requirements for Transmission Lines and Mains §§ 192.301–192.328 Inspection of materials, installation of pipe in ditch, under ground clearance, cover Subpart H -- Customer Meters, Service Regulators, and Service Lines §§ 192.351–192.385 Location of valves, meter operating pressure, excess flow valve installation, protection from damage Subpart I -- Requirements for Corrosion Control §§ 192.451–192.491 External corrosion control, protective coating, cathodic protection, monitoring Subpart J -- Test Requirements §§ 192.501–192.517 Strength test requirements for steel pipeline to oper ate at a hoop stress of 30 percent or more of SMYS, requirements for service lines, requirements for plastic pipelines Subpart K -- Uprating §§ 192.551–192.557 Requirements for increasing operating pressure above the previously established maximum pressure continued Read the entire page →
From page 68... ... 68 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS Subpart L -- Operations §§ 192.601–192.631 Procedural manual for operations, maintenance, and emergencies; surveillance; damage prevention pro gram; emergency plans; public awareness; maximum and minimum allowable operating pressure; odorization Subpart M -- Maintenance §§ 192.701–192.755 Patrolling, leak surveys, pressure limiting and regulating stations, valve maintenance Subpart N -- Qualification of Pipeline Personnel §§ 192.801–192.809 Qualification program and recordkeeping Subpart O -- Gas Transmission Pipeline Integrity Management §§ 192.901–192.951 Subpart P -- Gas Distribution Pipeline Integrity Management (IM) §§ 192.1001–192.1015 Definitions (including small LPG operator) Read the entire page →
From page 69... ... 69 T A B L E 4 -5 F ed er al P ip el in e Sa fe ty R eq ui re m en ts ( 49 C FR P ar t 19 2) Read the entire page →
From page 72... ... 72 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS Presented with this large list of additional Part 192 requirements and lacking all but the most basic information about LPG systems with 100 or fewer customers, the committee was not in a position to assess each requirement individually for applicability. Accordingly, the committee asked LPG industry representatives to provide their views on the Part 192 requirements, including their reasoning for wanting some or all the requirements to be eliminated or eased for systems having 100 or fewer customers. Read the entire page →
From page 73... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 73 They claimed these inspection and testing requirements are excessive in light of common industry practices and NFPA requirements for the • Inspection of tank and associated equipment condition that occurs during LPG delivery operations, • Operating test and inspections for system leaks each time a new occupant moves in, and • Odorization test at LPG transfer (from production to individual transport modes) Read the entire page →
From page 74... ... 74 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS The Suburban Propane representatives reported that even for very small jurisdictional systems, the labor costs associated with developing and maintaining the added documentation required by Part 192 averaged about $750 per system.18 The suppliers complained that compliance with these requirements is made more burdensome by variability in state (and sometimes individual inspector) interpretations of what constitutes a compliant plan or program. Read the entire page →
From page 75... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 75 TABLE 4-6 PHMSA Enforcement Actions in Florida, Hawaii, and Wisconsin and in Connecticut by the State's Public Utilities Regulatory Authority, Jurisdictional LPG Pipeline Distribution Systems (all sizes) , 2011–2016 Actions by PHMSA in FL, HI, WI, Total Actions by State Regulator, CT Number of jurisdictional LPG systems (all sizes) Read the entire page →
From page 76... ... 76 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS eral and state regulations applicable to LPG systems. Only one other state, Maine, reported expenditures of this magnitude (~$150,000 per year) Read the entire page →
From page 77... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 77 quirements in Part 192 or NFPA 58 and safety benefits even if a chain of causation between violations and incident causes were established. However, with third-party excavation damage and unknown causes comprising the majority of incident causes (see Figure 3-1) Read the entire page →
From page 78... ... 78 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS in a recent National Academies of Sciences, Engineering, and Medicine report.19 While requirements for management systems are often flexible in the sense that they give regulated firms the ability to customize their programs in accordance with their circumstances, they can present implementation challenges for operators with limited technical expertise and can be difficult for regulators to assess consistently. The requirement that gas pipeline distribution systems implement distribution integrity management programs (DIMPs) Read the entire page →
From page 79... ... SAFETY REGULATION AND ITS APPLICABILITY TO SMALL LPG SYSTEMS 79 Box 4-3 Distribution Integrity Management Program A DIMP, which is required for gas pipeline distribution systems by Part 192 Sub part P, is intended to ensure the safe performance of a pipeline system through identification of system integrity threats and the development and execution of methods to prevent or mitigate them. Although DIMP requirements are intended to be flexible to allow for customization, a compliant program should include the following seven components that are demonstrated in a written plan with docu mentation submitted annually to PHMSA: • Knowledge of system infrastructure (e.g., location, configuration, size of system) Read the entire page →
From page 80... ... 80 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS Box 4-4 Issues Arising in the Debate About Extending DIMP Requirements to Operators of Small LPG Systems In issuing the DIMP rule in 2009,a PHMSA gave its reasoning for extending the requirement to LPG distribution systems. Comments to the rulemaking raised a number of concerns about the applicability of an integrity management rule to small LPG operators. Read the entire page →

From page 54...

... 54 This chapter reviews the safety regulatory framework for liquefied petroleum gas (LPG) pipeline distribution systems; the number, location, and size of the systems subject to the regulation; and the concerns raised by the LPG industry about the applicability, safety benefits, and compliance burden of federal regulations imposed on LPG systems serving 100 or fewer customers.