Comment from Douglas Staebler (4) Images attached
Douglas StaeblerSupportIndividual
Summary: The commenter, an experienced gas operations professional, argues that PHMSA should require customer metering facilities to be included in operators' Distribution Integrity Management Programs (DIMP). They advocate for the use of specific safety devices, such as break-away fittings and methane alarms, to mitigate risks at these vulnerable distribution assets.
With over 40 years of gas operations responsibility I am a true believer in the (properly applied) DIMP approach to enhancing the safety of the operators distribution system based on all influences that may be unique to the system they operate. We have seen great strides in identifying threats and reducing risks (Replacement of at-risks pipe, damage prevention, corrosion, etc.) through the operator's IM programs. I oversaw the operations of a large operator where we continually reviewed and enhanced the DIMP, and through this review process, we wisely broadened our DIMP focus to include the customer's meter sets. Every year there is a great number of metering facilities that are involved in accidents, fires, and incidents, where gas becomes a factor in the outcome of the event. There is a great deal of (affordable) reliable technology on the market that can be easily employed to address the risks with (regulated) gas metering assets that serve the customers. From my experience, every meter set is different and has a unique set of threats, risks, and level of consequence, and if properly evaluated would show the need for one or more of these safety devices. Devices such a a residential (slam shut) vent-free regulator, break-a-way shut off fittings, thermally activated fire safety shutoffs, and methane alarms for regulated assets inside the customers building. As operators, we like to believe that are meter sets are all safe and well taken care of, but that is simply not the case, and shame on us if we stick our head in the sand and not take action to enhance to include additional safety devices at the vulnerable distribution assets that are above ground and attached to every customer's structure. My request is simple, PHMSA needs to put at a notice that customer metering facilities must be included in the operators DIMP and the use of existing meter-based safety devices should be used where warranted. For example, a break-a-way fitting on the meter set in DC where the day care facility was evacuated just prior to the explosion would have likely shut off the gas when the vehicle struck the meter set. The threats were obvious, meter near alley way, no bollards, next to the only door for evacuation, riser embedded in concrete, urban area, high pressure gas. This should show up in a DIMP analysis and be addressed. There are hundreds of thousands of metering examples like this out there and the customers that live behind these meter sets deserve the extra level of gas safety. They pay the rates.
