Developing a Cost Effective 15-year Plan to Comply with the Gas MEGA-Rule – Part 4

Article 4 of Series

Developing a Customer Outreach Plan to Support a Gas Mega-Rule Mitigation Plan

This article is the fourth in a series to help operators create a successful and cost-efficient mitigation program to implement their 15-year plans in compliance with Part 1 of PHMSA’s Gas Mega-Rule. These articles will help operators understand some of the pitfalls they may encounter when implementing their 15-year plans, and to understand some of industry’s best practices to speed the implementation of their mitigation plan while being as cost efficient as possible.

About GTS

GTS has been helping operators across the country with their gas transmission and distribution engineering for over 20 years. For the past ten years, California gas utilities have been implementing a California regulation mandate similar to the PHMSA Gas Mega-Rule. GTS has been the leading gas engineering firm involved with their mitigation plans including the design of over 1,400 miles of in-situ hydrotests, hundreds of miles of pipe replacement, ILI upgrades in both dense urban and rural locations, hundreds of valve automation upgrades, HDDs, distribution main replacement, regulator station replacements, program management, and more.  GTS is also one of the leading consultants nationwide for helping operators establish a compliant Records Management Systems (TVC Records) (§192.67, 205, 517), perform MAOP Reconfirmation (§192.624), and Material Verification (§192.607), and develop a 15-year mitigation plan to comply with the requirements of the Gas Mega-Rule.

Regulation Mandate

On July 1, 2020, Part 1 of PHMSA’s Gas Mega-Rule went into effect. Many of the changes in the “Mega-Rule” are intended to mitigate factors that can lead to damaging pipeline incidents in the future. The Mega-Rule requires operators to:

• Establish an Integrity Management Plan and all required procedures documented by July 1, 2021;
• Verify 50% of pipeline mileage by July 3, 2028; and
• Verify 100% of pipeline mileage by July 2, 2035.

Operators will need to establish compliant Records Management Systems (TVC Records) (§§§192.67, 205, 517), perform MAOP Reconfirmation (§192.624), and Material Verification (§192.607), and develop a 15-year mitigation plan to comply with the requirements of the Gas Mega-Rule. Through best practice experiences and benchmarking, GTS believes the development of the processes, procedures, and documentation management are key components for operators to consider and perform to effectively implement these programs with long-lasting and excellent results.

Developing a Customer Outreach Plan

There are approximately 3 million miles of gas transmission pipeline in the United States.  While pipelines are extremely safe, several large, damaging pipeline incidents over the past ten years have gotten national press and has made some people living and working near gas transmission pipelines nervous and anxious.  While there are several good reasons to develop a customer outreach program as part of the implementation of your 15-year plan, one of the most compelling reasons is to inform the local residents and businesses about the safety inspections and improvements being performed on the segment of the pipeline near them and to ensure the pipeline continues to operate safely.  This information is very much appreciated and provides peace of mind for these customers.

A good customer outreach plan informs the residents and businesses of the projects being conducted before they happen, informs them of the benefits of an inspection or project, gives them an opportunity to ask questions, and tells them of the results of the safety work afterward.  There are multiple ways to reach out to customers prior to starting an inspection or construction:

• Open House. Hold an open house at a nearby gathering place and invite the local community to discuss the proposed remediation project. Have both customer reps and technical personnel attend to discuss the project. Hang maps and bring models that show how a hydrotest or other work are conducted.
• Door-to-door outreach. Have customer reps canvass the neighborhood and explain the project and answer questions.  Leave door hangers that explain the project and have a call back number if no one is home.
• Interactive Voice Response (IVR) calls. Call residents and businesses near the work sites with a recording explaining when the inspection or construction project will be starting, to expect some local traffic, and who to call if there are any issues. Also, once the project is completed, an IVR can be sent to explain the project is complete and was successful.
• Road Signs. Post large signs explaining the work, daily work hours, and calendar dates of the work.
• A letter to the local residents and businesses after the work is complete and informs residents of the success of the project and safety of the pipeline.

Another important aspect of a good customer outreach program is to train the personnel designing the project, conducting inspections, or performing construction how to talk to the public about the project.  On any large construction project, neighbors will stop by the job site and ask the workers about the project.  A best practice is to help workers understand how sensitive neighbors are to gas transmission pipelines and provide workers with a script on how best to describe to the community the safety aspects of the project being conducted.  Openness, kindness, and empathy at the job site can significantly ease customer concerns and improve customer satisfaction.  Also, conducting the work as professionals, with high efficiency, organization, cleanliness, and quality generates confidence that the pipeline inspection or mitigation work is being done properly and the pipeline is safe.

A customer outreach plan must also address other critical customer interactions that occur on these mitigation projects.  Here are a few examples:

• Landowners and their tenants. Many gas transmission lines cross large swaths of land that have farming, herds, or other large businesses.  It is important that project personnel, and in particular, members of the construction crew talk with both the landowners and their tenants, if any, before starting the project to understand the preferred access points to the job sites and whether there are gate closures or other requirements needed to protect the operation of the farm or business.  Many projects have experienced significant delays from being shut down when the company’s land agent forgets to inform project personnel or the construction crew of these requirements, or a landowner does not inform their tenants of the pending work.
• Urban businesses. When projects are in dense urban areas, the risk of significantly impacting local businesses increases.  When trenches or bell holes block driveway access from the street to the business, not only can it create tension at the construction site but has potential for the operator to receive damage claims. If construction does not make accommodations to provide temporary access to the business or compensate the business owner for lost business, complaints to the city can shut down a project and/or significantly delay the schedule.
• Industrial or Generation Customers. Very large customers can be significantly impacted by a project like a hydrotest that takes the gas pipeline out of service for several weeks.  Project engineers and project managers need to communicate with these customers early in the design phase of the project to understand whether these customers can shut their operation down for the pipeline outage duration, or whether the project needs to find a way to serve this load.  Usually, these large customers can work with the project team on a schedule and a design that will work for both the project team and the customer, but early communication is critical.  An example might be that an industrial plant plans a major overhaul of their facility in 18 months.  This would provide a window for the hydrotest team to conduct their work without implementing costly alternatives to serve this customer during the pipeline outage.  In other situations, the hydrotest can be segmented so that a very large customer loses gas service for only hours while the gas operator switches supply from one pipeline segment to another.
• Local governments and first responders. Local government and first responder awareness are key if a project involves a large segment of pipeline being blown down (gas released to atmosphere). Your customer outreach plan should include calls to these entities prior to the blowdown.  Sensitive customers may respond to the noise of the blowdown or the smell of gas and call the local authorities.  A phone call providing the timing of the blowdown to the local authorities can avoid a large response by police and fire and save the project from being shut down at a critical point in the project.  Additionally, projects requiring significant traffic control modifications should be planned in conjunction with the local permitting agency and first responders. Some jurisdictions will severely limit the work hours or work will be permitted for night work only to reduce traffic congestion. Early identification of these constraints and planning with your construction team can help develop an optimized plan in these situations.

Developing a comprehensive customer outreach plan is a best practice your organization should consider to improve communication with the community, increase customer satisfaction, and avoid costly delays while implementing your 15-year mitigation plan. GTS is ready to help provide any guidance or gas engineering services you need to help you comply with the Gas Mega-Rule. Please contact Joe Medina (JMedina@kleinfelder.com) for additional information.

In the next article in this series, we will cover developing a team to manage project outage clearances.