The federal government requires every LP gas operator to telephone a report of any "incident" and, for some operators, to follow it up with a written report. The federal government may also require the LP gas operator to file a “safety related condition” report and an “annual report”. This chapter describes briefly each of these reports.
NOTE: Check with your state agency for any additional state reporting requirements. These can include lower dollar amounts of damage, media covering the incident, response by local emergency responders, road closure or evacuation.
It is required to telephone an incident report at the earliest possible moment, but in any case within two hours:
This telephone report of an incident should include:
The telephone incident report is made to the National Response Center at:
TOLL FREE (800) 424-8802 IN WASHINGTON, D.C. (202) 267-2675 24 HOURS EVERY DAY
REMEMBER, WHEN IN DOUBT MAKE THE CALL! See 49 CFR 191.5 for further information.
With the exception of master meter systems, operators of LP gas systems making a telephone report of an incident must follow it up with a written report.
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Chapter I – 11/30/2000 Address for Incident Reports
All required incident reports must be submitted on Form RSPA F7100.1 to:
US Department of Transportation
Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration
Attn: Information Resources Manager, Room 2103
400 7th Street SW.
Washington, D.C. 20590
See 49 CFR 191.7 and 191.9 for further information.
OPS may require operators of LP gas systems to report certain safety-related conditions.
A written report must be filed within five working days after the operator first determines that a safety-related condition exists, but not later than ten working days after the day the operator discovers the condition.
Each operator who is required to file a safety-related condition report is also required to update the operations and maintenance plan to include instructions enabling personnel who perform operation and maintenance activities to recognize conditions that may be safety-related conditions.
Typical conditions that would need to be reported by an LP gas operator include:
Safety-related conditions that do not require a report include:
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Chapter I – 11/30/2000
See 49 CFR 191.23(b) for further information. Address for Safety-Related Condition Reports
All required written reports must be submitted to:
US Department of Transportation
Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration
Attn: Information Resources Manager, Room 2103
400 7th Street SW.
Washington, D.C. 20590
In addition, an LP gas system operator may be required to file a report with the state agency participating in the pipeline safety program. For further details on the filing requirements refer to 49 CFR 191.7. However, an operator must file a written report that contains all the information as specified in 49 CFR 191.25(b).
Operators of LP gas systems serving 100 or more customers from a single source must submit an annual report for that system. This report must be submitted on DOT Form RSPA F 7100.1-1. This report must be submitted each year, not later than March 15, for the preceding calendar year.
Address for Annual Reports
All required annual reports must be submitted to:
US Department of Transportation
Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration
Attn: Information Resources Manager, Room 2103
400 7th Street SW.
Washington, D.C. 20590
All operators of LP gas systems are required to maintain plans for operations, maintenance and emergency response activities. Most operators comply with this requirement by developing and maintaining a manual that incorporates these plans. The manual must be prepared before operation of an LP gas system commences and must be reviewed and updated once a year. The manual must be available at locations where operations and maintenance activities are conducted. This manual fulfills the requirements of 49 CFR Part 192.605.
NOTE: The Federal DOT/OPS or the state agency certified under the Pipeline Safety Act may after due process require the LP gas operator to amend its plans and procedures as necessary to provide a reasonable level of safety.
An operations and maintenance plan is required of all LP gas operators by the pipeline safety regulations. The operations and maintenance plan must be written and followed to help the operator comply with the pipeline safety regulations. See 49 CFR 192.603 for further information.
Each operator shall include in its written plan, procedures for all operations which may be performed on the LP gas system by the operator or on behalf of the operator.
The following is a discussion of some of the operations procedures which may be encountered in a typical LP gas distribution system
The operations topics covered here are:
Operating Pressure
Per the NFPA 58 (LP-Gas Code), first stage regulators shall have an outlet pressure up to 10.0 psig and incorporate an integral pressure relief valve, all in accordance with the Standard for LP-Gas Regulators, UL 144. These are typically factory set and non adjustable. This would limit the operating pressure of a typical newly installed system to a maximum of 10 psig.
In cases where the regulators in use are other than the 10 psig or less standard, further consideration must be given to setting an operating pressure, such as using an adjustable high pressure regulator with a 10 psig regulator between it and the second stage regulator(s). These situations might include a system put in service prior to the adoption of the 10 psig standard or where special order adjustable regulators are used.
The LP-Gas Code states that polyethylene piping systems shall be limited to vapor service not exceeding 30 psig. As discussed in Chapter III concerning materials, steel piping must be designed at either 125 psig, 250 psig or 350 psig.
These types of factors, based on material design and LP gas properties, can be used in conjunction with a pressure test conducted to verify the integrity of the piping system to arrive at an operating pressure. However, it is recommended operators of the small LP gas systems stay within the 10 psig standard for their distribution piping.
Operating pressure determination should be documented in the operator’s written plan.
Pressure Testing
Pressure testing must be performed to verify the integrity of the piping system prior to placing it into service, when newly constructed or upon subsequent modification. The LP-Gas Code states that this pressure test can be done at not less than the normal operating pressure. Most operators test at a higher pressure than operating pressure. It is recommended that all operators follow this practice.
Pressure tests should be documented by the personnel performing the test and copies should be maintained for the life of the syste
Information documented should include:
Tapping and Purging
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Tapping and purging operations should be performed in accordance with written procedures by personnel with documented qualification in the use of those procedures (i.e. the LP gas distribution system operator should obtain and maintain copies of the qualifications of the individuals performing this operation). A good source of procedural information is the American Gas Association (AGA) Operating Section Report entitled Purging Principles and Practice. It is recommended that a purge medium, such as nitrogen, be used, if practical, or as a slug between air and gas. Water may also be used where the system will not be placed back in service. If air is used, care should be exercised to ensure that a flammable mixture of LP gas and air is not created. An instrument, such as a combustible gas indicator, should be used to verify gas purged in or out of the system. Points of introduction of purge medium and venting should be chosen to thoroughly purge the piping system.
Information documented should include:
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Odorization
The LP-Gas Code specifies that LP gas be odorized prior to delivery to the bulk plant. It goes on to require verification by “sniff-testing or other means, and the results shall be documented” when gas is delivered to the bulk plant or in the case where a delivery bypasses the bulk plant. If the documentation required by the LP-Gas Code is not available to the LP gas system operator, then the operator will need to do his own sniff tests to verify odorization and document the results.
Testing for Reinstating Service Lines
The written plan must contain a provision for testing (before placing in service) each service line that is disconnected from the main in the same manner as a new service line (49 CFR 192.725). Test procedure and documentation are discussed above.
Abandonment or Deactivation of Facilities
The written plan must include provisions for shutdown, abandonment or deactivation of facilities (49 CFR 192.727). When a gas main or service line is abandoned, it must be physically disconnected from the piping system and open ends effectively sealed. In addition, the operator must determine the necessity of purging the line. Note: Take into consideration the location and size of the main or service. As a recommendation, pipe two inches and larger should be purged.
In cases where the main and all the service lines connected to it are abandoned, the service line(s) must be capped at the customer’s end. Also, the abandoned main must be sealed at both ends.
When service to a customer is temporarily or permanently discontinued, one of the following must be done:
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Construction Records, Maps and Operating History
Construction records should include detailed construction plans, modified as appropriate to show the as-built condition of the facilities. These plans and maps should show in detail, the location of all facilities and date of installation. Maps should have enough detail to accurately determine the physical location of all facilities.
A detailed bill of materials should be included. This should provide specifications of the materials used, including manufacturer, size (diameter, wall thickness, etc.), pressure rating, manufacturing standard, etc.
Additional construction records may include:
All system modifications should be recorded in detail.
Operating history should include records of all system modifications and repairs, areas of active corrosion, history of areas susceptible to damage and operating pressure records.
Unaccounted For Gas
LP gas systems serving 100 or more customers from a single source are required to file an annual report. Part of this report must be the system’s percentage of unaccounted for gas. Unaccounted for gas is the difference between the amount of propane delivered into the system and the amount that is recorded through the customers’ meters. Unaccounted for gas can be caused by measurement and control errors, system leakage and theft.
Temperature and pressure affect gas density. For this reason, temperature-compensating meters are widely used. For customers with high gas usage, the meter can be located upstream of the second stage pressure regulator so that a smaller (less costly) meter can be used. Where the meter is located upstream of the second stage pressure regulator, a constant pressure must be maintained. Otherwise meter readings will not be accurate and can lead to an amount of unaccounted for gas. Pressure-compensating meters are available.
The better the control on gas measurement, the easier it is to spot problems in other areas that affect unaccounted for gas.
During the required periodic maintenance checks that are required by the Federal Pipeline Safety Regulations, operators should observe the system to ensure that there are no violations of NFPA 58.
Some of the areas to check are: Loose combustible materials are not stacked within ten feet of the LP gas tank.
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If a security fence is required, it is in adequate repair. All necessary gates are accessible in case of an emergency. Gates are locked when operator personnel are not present.
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Important buildings have not been added closer to the tank(s) than permitted in NFPA 58.
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Signs that are required on some installations are being maintained.
Maintenance plans must contain the following components:
Pressure Limiting Devices
It is important that all systems operate within their intended acceptable pressure limits. Devices must be maintained annually to ensure that they are:
in good mechanical condition capacity is adequate set to function at correct pressure properly installed and protected from vehicular traffic, dirt, liquids, icing and
other conditions that might prevent proper operation Lock up testing and/or the use of pressure recording devices are ways to prove regulator stability. First stage regulators are now required to have built-in pressure relief devices per NFPA 58, unless the capacity of the regulator is more than 500,000 Btu/hr. In this case a separate pressure relief valve may be used.
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Some LP gas systems use vaporizers in their systems. Hydrostatic relief valves and vaporizer relief valves are normally part of a system that uses vaporizers. The O&M plan should include the methods in which all pressure limiting devices are maintained.
Patrolling
Although this is normally not necessary for small LP gas systems, if a condition exists in the area of an LP gas system where anticipated movement of the pipeline could cause failure or leakage (e.g., weight from construction, area prone to wash out, etc.), then the pipeline shall be periodically patrolled until the condition no longer exists. The frequency of the patrolling must be determined by the severity of the conditions which could cause failure or leakage and consequent hazards to safety, but no fewer than four times each calendar year in the business district or twice each calendar year outside of the business district.
Example of a washout area found by patrol.
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Key Valves
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Key valves, or critical valves, are the valves needed to shut down the LP system, or part of the LP system, in the event of an emergency. For many LP gas systems, this would be the container main valve. Key valves should be checked at least once per year to ensure that they are operable. Procedures for maintaining these valves must be included in the maintenance section of the O&M Manual.
Accidental Ignition of Gas
The plan must include provisions to prevent the accidental ignition of gas. LP gas alone is not explosive but when mixed with air in a concentration of 2.15% to 9.6% for propane, it can ignite or explode. Every precaution should be taken to prevent unintentional ignition of LP gas. When venting gas to the air a fire extinguisher must be available and positioned for immediate use.
Leak Survey
A survey of an LP gas distribution system must be made as frequently as necessary, but at intervals not exceeding five years. If part or all of the system is located in a business district, a gas leakage survey must be conducted at least once every year. Procedures on how to conduct leak surveys must be included in the maintenance section of the O&M manual.
Some LP gas operators use contractors to leak survey their systems. It is the responsibility of the operator to ensure that the survey is conducted in accordance with the pipeline safety regulations. The operator must retain a report describing the results of each survey.
LP gas operators must do a subsurface type of survey when using gas detection equipment to perform their survey. Although an FI (Flame Ionization) unit may be used to assist in the survey, a CGI (Combustible Gas Indicator), must be used for pinpointing leaks and classifying them.
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Many LP gas operators opt to do a pressure drop test to prove the integrity of their pipeline. This is normally done on smaller systems, where shutting off the customers is not a problem. A very important thing to consider is, if you do have any drop in pressure, then you must do a subsurface survey using a CGI meter. A pressure drop test tells you if you have a leak. It does not tell you the location of the leak or its classification.
Other things to consider when doing a pressure drop test are:
the time for the test medium to become temperature stabilized and the sensitivity
of the instrument being used.
An advantage of doing this type of test is that the first stage regulator can be tested for lock up at the same time. Some operators use a portable supply tank on certain systems, and temporarily connect it into a tee just before the second stage regulator. With the proper valving installed ahead of time, they can perform a leak test of the piping and lock up on the regulator without shutting down the system.
For more information on performing leak surveys see Chapter X. This chapter includes useful information from AGA and the Gas Pipeline Technology Committee.
Corrosion Testing
Underground steel mains, including underground tanks must be tested annually to prove that the systems are being cathodically protected. Although there are five acceptable methods of testing, the most common method being used for small systems is the negative 0.85 dc volt criteria. Aboveground piping and tanks must be inspected for atmospheric corrosion at no longer than three year intervals, although for many LP gas systems it is easy and good practice to observe the condition of the aboveground piping during other annual maintenance. For more information on corrosion and compliance refer to 49 CFR Part 192 Subpart I and CHAPTER VIII of this manual.
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Each operator is required to maintain a written plan of procedures and other necessary information to meet LP gas emergency situations. The federal regulations for emergency plans are contained in 49 CFR Part 192.615 of the federal Pipeline Safety Regulations. It is also the responsibility of the LP gas operator to be familiar with all state and local regulations as they apply to emergency situations regarding their piping systems.
The written emergency plan should contain the following information:
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It is important for all responders to know their limitations. They should not take undue risks that may endanger their personal safet
5. CHECKLIST FOR A MAJOR EMERGENCY– Every item may not be necessary.
______ 1. Has the fire department been called?
______ 2. Have persons been evacuated and the area cordoned off?
______ 3. Has police department been notified?
______ 4. Has repair crew been notified?
______ 5. Has company call list been implemented?
______ 6. Has communication been established?
______ 7. Has outside assistance been requested?
______ 8. Have ambulances been requested?
______ 9. Have emergency valves to shut down or reroute the gas been identified and located?
______ 10. Has leak been shut off or brought under control?
______ 11. Has civil defense or local emergency response crew been notified?
______ 12. Has the radio and/or television station been given emergency broadcast instructions?
______ 13. If an area has been shut off, have the individual services in the area been shut off?
______ 14. Is the situation under control and has the possibility of recurrence been eliminated?
______ 15. Has the surrounding area, including adjacent buildings been probed for the possibility of further leakage?
______ 16. Have tags been placed on the necessary meters?
______ 17. Have telephonic reports been made to the state or local regulatory agencies?
______ 18. Has a telephonic report been made to the federal Office of Pipeline Safety National Response Center?
Date ______________________________
6. REPORTING REQUIREMENTS; BOTH TELEPHONIC AND WRITTEN REPORTS -In the case of an incident, a telephonic report must be made within two hours to the National Response Center (1-800-424-8802). In Washington, DC, the telephonic report is made to 267-2675.
An incident is an event involving the release of gas from a pipeline system and:
A written report must be submitted on USDOT Form RSPA F7100.1 as soon as practicable, but not more than 30 days after detection of an incident. Master meter systems must make the telephonic report but are exempted from the written report.
The address for written incident reports to the federal government is:
Information Resources Manager Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration USDOT, Room 7128 400 Seventh Street, SW Washington, DC 20590
7. PLAN FOR RESTORATION OF SERVICE AFTER AN OUTAGE – Qualified persons must follow proper written procedures to safely restore service after an outage. The procedures must include details for re-lighting appliances.
Gas service must be restored on a building-by-building basis throughout the affected area. First, service to each customer must be shut off, either at the meter or at a curb valve. If this cannot be done, the gas flow can be shut off by squeezing off the line.
Before restoring service to an affected area, all gas piping and meters must be purged of air. Then re-lights can be accomplished. Never turn on the gas at the meter unless access is available to all appliances on the customer piping. If the operator cannot get access to a customer’s building facilities, notification must be left in a conspicuous location requesting the customer to call the LP gas operator to schedule the restoration of service.
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The person in charge of the restoration of service must accept the entire responsibility for following the written procedures.
A written record of the incident with all necessary information, including the information on restoration of service, must be kept in a permanent file.
8. ACCIDENT INVESTIGATION PROCEDURES – Each operator must establish written procedures for analyzing accidents and failures to determine the cause of the failure and minimize the possibility of recurrence. The procedures must include:
9. EDUCATION AND TRAINING PLAN – Operating personnel and other emergency responders must be qualified to ensure understanding of emergency procedures and equipment. It is the responsibility of the operator to conduct adequate training and to keep records of the training. Training should include:
The operator also has a responsibility to conduct a continuing education program that enables customers, the public and excavators to recognize and respond to emergency situations. The education program can include:
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This educational information may be conveyed to the interested parties by a number of means, including:
If a significant percentage of the population in the operator’s area does not speak English, the education and training must be conducted in a language understood by the non-English speaking community.
The operator must maintain records of the public education program.
Many excellent educational pamphlets and other training aids are available from the National Propane Gas Association. \Their address is:
National Propane Gas Association 1600 Eisenhower Lane, Suite 100 Lisle, IL 60532