2009 Natural Gas Safety Framework Report to the Minister

Transcription

1 2009 Natural Gas Safety Framework Report to the Minister 1 P age

2 Foreword The CER has taken on an important function of gas safety since the enactment of the Energy (Miscellaneous Provisions) Act at the end of We have discharged this obligation through the establishment of a Natural Gas Safety Regulatory Framework (the framework) in which we aim to reach a position in Ireland that meets best international practice. The framework aims to protect natural gas customers and the public generally from hazardous events ranging in frequency and severity, and ensures that adequate measures are taken to protect life and property from the dangers associated with natural gas. This includes all natural gas storage, transportation, supply and use activities onshore in the Republic of Ireland. The CER has engaged with the natural gas industry to ensure that gas undertakings can demonstrate to the CER s satisfaction that safety is a prime consideration in the operation of their businesses. The industry has presented safety cases to the CER which have been rigorously scrutinised and will be subjected to ongoing assessment and inspection. The 2006 Act specifically requires the CER to regulate onshore natural gas undertakings and registered gas installers with respect to safety and to promote the safety of natural gas customers and the public generally. The Framework identifies key methods for safety management including the promotion of gas safety; the management and demonstration of operational risk through a safety case; registration and inspection of gas installers; reporting and investigation of natural gas incidents; and management of safety performance through reporting, review, inspection and audit requirements. The key areas of activity during 2008 and 2009 saw the majority of undertakings having completed an acceptable safety case, and the full establishment of the Register of Gas Installers of Ireland and the registration of natural gas installers. 2 P age

3 Also during 2009 following diligent involvement in a number of fatal, LPG related, Carbon Monoxide incidents a number of proposals were developed to bring the safety regulation of LPG activities under the auspices of the CER; this includes LPG installers and LPG distribution systems. It is evident that this framework will develop and grow to accommodate learning and evolving legislation and it is expected that 2010 will see some further framework implementation. There were no fatalities due to natural gas transportation, supply or utilisation during the year, with one incident on the natural gas pipe system and threee incidents involving customer s gas installations. The first year of reporting on the gas distribution and transmission activities also returned a good level of performance and many safety improvements were realised, including near completion of the cast iron mains replacement programme, removal of significant numbers of potentially dangerous appliances from customer s premises and a reduction in vandalism related incidents. The CER remains committed to continuing and developing industry safety performance and working with consumers and industry to provide a safe supply of energy to customers, and will continue to tackle gas safety challenges into Michael G Tutty Chairman November Dermot Nolan Commissioner Garrett Blaney Commissioner 3 P age

4 Report Summary This report summarises the performance of the natural gas undertakings regulated under the Framework, through analysis of incidents, operational statistics and technical inspections and audits, and compares performance against prescribed high level objectives. The Commission also ensures that each undertaking manages risk through a safety case where asset based risk is evaluated and managed. The 2009 period has seen strong progress in implementing the requirements of the Energy (Miscellaneous Provisions) Act Safety Case regimes are now fully operable for gas transportation (transmission and distribution) operations, with many shippers and suppliers also completing the safety case development process. The following undertakings have submitted acceptable safety cases to the CER to date (June 2010): Undertaking/Licence Transmission Distribution Gas Storage Shipper/Supplier Gaslink PSE Kinsale Energy* Bord Gáis Energy Gazprom ESB Manx Electricity Auth. Energia Flogas Airtricity Tynagh Aughinish Alumina Huntstown Phoenix Energy 4 P age

5 *Gas Storage (Interim) safety case from Marathon Oil Ireland Ltd was assessed and accepted by the CER in February Following a change in ownership a revised safety case is pending. The mandatory requirement for gas installers to be registered also progressed significantly in 2009, with the appointment of the Register of Gas Installers of Ireland (RGII) as the new regulatory body responsible for registering and inspecting the work of natural gas installers (Registered Gas Installers). Firm operational protocols were also established for the registration of gas installers which facilitated the transition of around 2,700 installers onto the RGII. A gas safety promotion strategy and programme has also been established with an active itinerary, including press, radio and television advertising. The CER also carried out a national road show, presenting to installer groups and addressing individual and collective concerns. There were four significant natural gas related incidents during 2009, none of which involved any fatalities or serious injuries. One incident was due to a damaged external gas main, the other three due to issues with customer s gas installations. One incident in Blackrock, Dublin caused significant property damage. Incident Location Incident Date Incident Type* Learning Outcomes Grand Parade, Dublin 10/01/2009 NR Y Temple Road, Blackrock, Co. Dublin 14/03/2009 B N Milltown Drive, 18/12/2009 C Y Dublin Donore Road, Dublin 19/12/2009 C Y * Denotes incident type: A Involves a fatality; B Injury requiring hospitalisation; C property damage in excess of 6,350; NR A non reportable incident that may have other significance or learning. 5 P age

6 Incidence of gas escaping following a pipe or installation fault, or pipe damage, is falling year on year. The year has also seen performance or technological improvement in pipeline protection, corrosion management, and pressure control. Management of gas quality parameters (ensuring components in gas remain within safe limits) and odorant (added to give gas a distinctive smell) has been highly efficient. Response to customers reporting gas escapes maintained high performance levels, with only 17 responses out of 20,332 taking longer than 1 hour; this was due to flooding and snow. It is notable that there were two fatalities following a Carbon Monoxide incident at Glenties, Co. Donegal during September. These related to an LPG cooker installation. The CER provided substantial support to the ensuing investigation. The CER s Safety Division have worked closely with the DCENR in developing new proposals for LPG which were recently released for industry consultation. These proposals form the basis for planned legislative changes to bring LPG safety regulation under the CER s auspices. 6 P age

7 Introduction The purpose of this report is to provide a summary of the safety performance of the natural gas industry during 2009, with particular focus on the Natural Gas Safety Framework and the processes that are encompassed by it. The report will identify the principal objectives of this framework, describe developments during 2009 and provide analysis and review of safety performance and compliance. Following the enactment of the 2006 Energy (Miscellaneous Provisions) Act (the 2006 Act) the Commission for Energy Regulation (CER) was required to introduce new measures to regulate the safety performance of the Irish Natural Gas industry. The scope of this legislation encompassed all industry boundaries and included undertakings in gas storage; transportation; commercial gas supply and shipping; and safe gas utilisation. Such a remit required safety regulation of both semi state and private businesses through active and responsive risk management strategies. During 2007 a safety vision and strategy was developed for the foreseeable industry picture and wide ranging industry consultations were instigated. The result was to develop and implement a Natural Gas Safety Regulatory Framework (the Framework). The current Framework is illustrated in Figure 1 below and is constantly evolving. The generic strategy is twofold; firstly to ensure that industry safety requirements were fulfilled competently and; to promote and develop public perception, and therefore knowledge, of gas safety. The strategic objective of the framework is: To ensure that adequate measures are taken to protect life and property from the dangers associated with natural gas by ensuring that gas related activities within the scope of the Commission s responsibilities are carried out in a safe manner, 7 Page

8 which takes account of and mitigates against the risks associated with the storage, transportation, supply and use of gas. To develop a practical solution it was then necessary to identify the high level safety targets and functional safety controls. These principal objectives are as follows: Key Objective 1: Minimising the Risk of Loss of Containment Gas undertakings will be required to demonstrate that they have suitable management systems and procedures in place for managing the risks that lead to, and arise from, loss of gas containment events. Key Objective 2: Maintaining Safe System Operating Pressure Gas undertakings will be required to demonstrate that they have suitable management systems in place for managing the risks that can result in dangerously high or low gas operating pressure in the pipeline system(s). Key Objective 3: Minimising the Risk of Injecting Gas of Non Conforming Quality Gas emergency incidents can arise due to gas of inappropriate quality being injected into the system and, as such, gas undertakings will be required to demonstrate that they have suitable management systems in place for gas quality monitoring and for managing the risks associated with the quality of gas that is injected into the system. Key Objective 4: Providing an Efficient and Coordinated Response to Gas Emergencies 8 P age

9 Gas emergency events can and do occur for a variety of reasons including the actions of third parties. Bord Gáis Networks will be required to demonstrate that it has suitable arrangements in place for: (i) managing the response to localised gas emergencies; and (ii) undertaking the role of Network Emergency Manager during network gas emergencies. Additionally, all gas undertakings will be required to demonstrate that they have suitable arrangements in place for responding to the requirements of the Network Emergency Manager in the event of large scale network gas emergencies being declared by the Network Emergency Manager. As stated in section 5.4 below, the operators of major accident hazard facilities such as LNG terminals and gas storage facilities have responsibility for the on site management of gas emergencies within the confines of their installations. The role of the NEM in such circumstances is to manage the downstream impacts of such emergencies within the transmission and distribution networks. Key Objective 5: Minimising the Safety Risks Associated with the Utilisation of Gas The Framework provides for a comprehensive regime relating to the regulation of gas installers. The key aim of this regime is that all categories of gas works designated by the CER are only undertaken by competent gas installers who are registered, and subject to ongoing regulation and inspection, by the Gas Safety Supervisory Body appointed by the CER. The connection and re connection of customers installations to the gas supply network and the servicing of such installations is an important safety risk issue that will be addressed within the scope of this objective. Customer education and safety awareness is also an important part of this gas safety objective as discussed in key objective 6. 9 P age

10 Key Objective 6: Promoting Public Awareness of Gas Safety Increasing the level of gas safety awareness amongst gas customers and the public generally and, in particular, educating on the dangers of carbon monoxide is an important aspect of the CER s overall objective of promoting the safety of customers and the general public in respect of the use of gas. It is also important that owners/occupiers of premises are aware of their responsibilities in respect to the maintenance of gas fittings downstream of the meter. To this end, the Framework places duties and obligations on both individual gas undertakings and the industry generally for the promotion of gas safety awareness. This involves a combination of both individual and co ordinated safety promotional activities by undertakings. These key objectives provided the foundation to develop the components of the gas regulatory safety framework, which would provide data and information to enable key performance measures to be implemented. The component parts of the framework are described below as: a) A Gas Safety Case regime, which uses a risk and outcomes based approach to the management of gas safety risks to a level that is as low as reasonably practicable, for each licensed undertaking; b) A Gas Safety Supervisory Body responsible for the registration of gas installers that meet specified criteria of training and competency, and subsequently regulates gas installers via an ongoing inspection and audit regime of work against specified standards; 10 P age

11 c) A Gas Safety Promotion and Public Awareness regime that is designed to increase the overall level of gas safety awareness amongst customers and the general public on gas safety matters based on coordinated and individual undertaking s safety promotional activity; d) An Incident Reporting and Investigation regime that fulfils obligations for the reporting and investigation of incidents by Bord Gáis Networks, the reporting on the outcomes of incident investigations by Bord Gáis Networks to the CER, independent CER investigations and subsequent reports by the CER to the Minister. This will also include for incident reporting and investigation requirements by the operators of major accident hazard facilities e.g. LNG and gas storage operators. e) An Audit and Inspections regime that the CER will use to gain assurance that the various undertakings are operating in compliance with the gas safety management and emergency response arrangements as described in their respective safety cases, and the Gas Safety Supervisory Body in accordance with its Terms and Conditions of Appointment; and f) A Gas Safety Reporting Framework that utilises a suite of gas safety performance indicators to monitor trends and provide assurance that the intended outcomes of the Framework are being achieved. 11 P age

12 Minister for Communications, Energy and Natural Resources Incident Investigation and Reporting to Minister Energy (Miscellaneous Provisions) Act 2006 Strategic Approach to Gas Safety Regulation Non-Prescriptive Approach Appropriate Regulation Relevant to a Liberalised Gas Market Risk and Outcomes Based Commission Role of Securing Compliance Natural Gas Safety Regulatory Framework Strategic Safety Objective To Ensure the Protection of Life and Property Gas Safety Regulatory Objectives (KPI s) Minimising Risk of Loss of Containment Maintaining Safe System Operating Pressure Minimising the Risk of Injecting Gas of Non-Conforming Quality Providing and Efficient and Coordinated Response to Gas Emergencies Minimising the Safety risks Associated with the Utilisation of Gas Promoting Public Awareness of Gas Safety Gas Incident Investigation and Reporting Regime Gas Safety Case Regime Safety Case Guidelines Facility Description Formal Safety Risk Assessment Safety Management System Emergency Procedures Safety Reporting Framework Gas Safety Promotion and Public Awareness Coordinated Safety Advertising Promotion of Gas Safety Gas Safety Initiatives Gas Safety Forum Gas Safety Supervisory Body Registration of Gas Installers Safety Inspections & Audits Investigation of Complaints Analysis of Safety Outcomes and Continual Improvement Process CER Licensed Gas Entities LNG Terminals Safety Case Guidelines Storage Operators Safety Case Guidelines Transmission Safety Case Guidelines Distribution Safety Case Guidelines Shipping & Supply Safety Case Guidelines Natural Gas Installers and Installations Safety Case Safety Case Safety Case Safety Case Safety Case Audits and Inspections Regime Major Emergency Plans and NEM Framework Safety Reporting Safety Reporting Safety Reporting Safety Reporting Safety Reporting Natural Gas Safety Reporting Gas Industry Safety Reporting Regime Incident Reporting Participant Quarterly Reports to Commission Commission Annual Report to Minister Figure 1: The Natural Gas Regulatory Framework 12 Page

13 Annual Framework Development Report for 2009 The Framework has seen considerable development during This activity ranges from establishment of the Register of Gas Installers of Ireland (RGII) and handover from the earlier voluntary scheme; development of criteria for inspections and audit processes; early work on expanding the scope of the framework to include LPG and implementation of Framework strategies for safety cases, safety promotion, incident investigation and safety reporting. The following summary seeks to capture these works by Framework function: Gas Safety Case Regime The principle for requiring a safety case places an onus upon gas undertakings to actively identify, review and demonstrate risk based management processes that quantify the risks of operating their businesses. It also drives the undertaking to develop continuous improvement philosophies which iterate and grow an improving safety profile. The start of 2009 saw the distribution and transmission undertakings begin fully reporting operational performance using a series of Key Performance Indicators (KPI s) and the first functional audits of the same undertakings. The safety case assessment process seeks to establish if each undertaking has adequate arrangements in place to competently manage the foreseeable operational risks posed by their assets. This enabled the CER to develop a fuller picture of asset risk and performance to ensure, as far as is reasonably practicable, the safe operation of the gas assets. 13 P age

14 Safety Cases are also required from gas shippers, suppliers and storage operators also saw significant inroads made to develop and implement safety cases in many of these areas, with the majority of shippers and suppliers now having an approved safety case. Register of Gas Installers Ireland (RGII) Under the 2006 Act, the CER designated the Register of Gas Installers of Ireland (RGII) as the Gas Safety Supervisory Body (GSSB) to undertake the regulation of natural gas installers with respect to safety on November 6 th The process of registering gas installers began immediately, and it subsequently became mandatory for any party wishing to carry out domestic gas work to be registered (as a Register Gas Installer, or RGI) on the 26 th June The CER worked closely with the GSSB to ensure that all of the relevant protocols, procedures and agreements were developed to facilitate and support this process. The CER agreed with industry stakeholders to a transitional period where installers could join provisionally ; the aim was to enable installers some time to register, obtain qualifications and provide proof of indemnity. This period ended on 18 th December 2009, with agreement that any installers registered with the RGII at that date and undertaking a training course could finish the course, within a reasonable timeframe. At the end of 2009 there were 2,667 individuals registered as Registered Gas Installers operating under the scheme. Also during 2009 the Bord Gáis inspectorate transferred to the new RGII and it is the RGII who now carry out the inspection and audit program to ensure RGI s are competent and that their work meets the required national standard. 14 P age

15 In order to enforce the registration requirements 37 cease and desist letters issued individuals and companies operating outside of the RGII requirements. This is the first warning applied to installers who are identified as not registered. Gas Safety Promotion and Public Awareness The CER Safety Division chairs and oversees an industry group (the Gas Safety Promotion and Public Awareness Group) which is dedicated to the development and review of the national gas safety promotion and public awareness activities. The activities of this group include all media promotions, safety surveys, public awareness initiatives and promotions external to the industry. The scope of activities includes areas such as: Utility damage prevention Carbon Monoxide Safe use of gas Gas escape awareness Register of Gas Installers Emergency preparedness and response Past initiatives have included working with the Health Service Executive (HSE), Fáilte Ireland, General Practitioners, Health & Safety Authority (HSA), ESB, Local Authorities, National Standards Authority of Ireland (NSAI) and the Irish Liquefied Gas Association (ILPGA). The objective of the Programme is to achieve the following 5 outcomes: 1. Increased levels of general public awareness of gas safety issues; 15 P age

16 2. Greater willingness among the general public to take preventative actions with respect to gas safety; 3. Greater willingness among the general public to take positive actions with respect to gas safety; 4. High levels of awareness of, and confidence in, the Register of Gas Installers amongst the general public and the installer industry; and 5. Raised levels of general awareness of the Commission s role as the regulatory authority for gas safety matters in Ireland. The year saw the development of a cohesive strategy for this process and the development of a detailed programme of activity for This programme continues the existing advertising activity and also currently seeks to develop awareness of the Register of Gas Installers and Carbon Monoxide safety. Gas Industry Reporting Regime This annual gas safety report forms part of the evolving reporting strategy which has been gradually implemented since the 2006 Act came into force. Criteria for the reporting and investigation of gas incidents have been established for a number of years, however, inclusion of this data in the wider reporting regime and the ability to utilise this data collectively with undertakings reports, is a developing concept which enables the CER to obtain a fuller picture of risk management. More significantly this permits the CER to make collective judgements and positive interventions where necessary. It also determines the requirements for audits and inspections which may be planned or sporadic in nature. All data is monitored continually and reviewed quarterly to coincide with undertakings reporting frequencies. Gas Safety reports are developed every quarter and presented by the Safety Division to the CER Commissioners. 16 P age

17 Framework Development Initiatives LPG There is an ongoing iterative process for existing framework requirements requiring review and consultation with natural gas undertakings. The 2006 Act made provision for the inclusion of Liquefied Petroleum Gas (LPG) within the framework. However, it became clear on fuller analysis that the legislative framework required further development to fully capture all relevant aspects of the LPG supply chain which needed to be subjected to safety regulatory oversight by the CER. Following a number of recent incidents involving LPG the need for this inclusion has been accelerated and currently work is ongoing to fulfil this intention in close co operation with the Department. The CER Safety Division published a consultation paper on 22 nd May 2009 seeking comment and recommendation on the safety regulation of the LPG industry. Following this consultation a legislative consultation paper was published on the 4 th February 2010 seeking views on the proposed scope and delineation of responsibilities for the safety regulation of the LPG industry, particularly with regard to the interface with safety legislation and the HSA. The proposal seeks to address regulation of aspects of the LPG industry not currently encompassed by existing legislation and includes: LPG installers and LPG installations with respect to domestic, commercial and industrial premises; LPG distribution networks with respect to underground pipe systems (but not the central LPG storage tank as this aspect is covered under Dangerous Substances (Storage of Liquefied Petroleum Gas) Regulations 1990); LPG appliance related incident reporting in a domestic setting; and The need for statutory responsibilities to be placed on undertakings to promote the safety of LPG customers and conduct LPG safety campaigns with respect to the safe utlilisation of LPG. 17 P age

18 Natural Gas Safety Performance Report The ongoing reporting and continuous improvement philosophy which underpins the Framework has led to the formulation of a performance reporting process which provides information to enable the CER to form a judgement on the performance, and ultimately the compliance, of natural gas undertakings and supervisory bodies with the requirements of the Framework. This reporting process is developing and incorporates learning and feedback from all parties involved to provide Key Performance Indicators (KPI s) of whether safety objectives are being achieved. Data from undertakings reports, inspections, audits and incidents are reviewed and remedial actions are addressed in consultation with affected groups. This information identifies both corrective and preventative actions and learning forms the basis for audit and inspection routines to provide assurance and any iterative improvements. Outcomes and actions are regularly reviewed and the CER s Safety Division reports trends and findings on a quarterly basis to the Commissioners. The format for reporting follows progress against the six key safety objectives and is continually reviewed as the framework develops. 18 P age

19 2009 Incident Reporting Summary There were four significant natural gas incidents during 2009, none of which caused serious injury or fatality. The criteria for incident reporting has been established and operating for a number of years with Bord Gáis Networks and operates around an agreed definition of reportable incidents. The CER also has criteria for non reportable gas incidents where, in the interests of learning, less significant gas incidents are analysed and reviewed. The reportable incidents during 2009 may be summarised as follows: Damaged Gas Main at the Junction of Dartmouth Place and Grand Parade Dublin 10/01/2009 On 10 th January 2009, employees of Gerry McCloskey (GMC), a contractor carrying out work on the Bord Gáis distribution network in Dublin on behalf of Bord Gáis Networks (BGN), damaged a 4 bar gas main with an excavator resulting in an uncontrolled gas escape. The gas escape forced the closure of Grand Parade and the LUAS Green line for approximately 3 hours and left three commercial buildings without gas. No one was injured in the incident. The investigation revealed that the operatives were operating a mechanical excavator in close proximity to the main. The CER Safety Division recommended that Bord Gáis issue guidelines for working near buried plant and concrete. Since the incident additional training has been completed. Precautions for working around buried concrete were also issued. 19 P age

20 Explosion at 35 Temple Road, Blackrock, Co. Dublin 14/03/2009 An explosion occurred at around lunchtime on the 14 th March 2009, causing considerable damage to three terraced properties and minor injuries to occupants and passers by. A number of motor vehicles and surrounding properties were also damaged. The subsequent investigation identified that a fitting had been removed on the customers gas installation near to the central heating boiler, leaving an open ended pipe to allow gas to enter number 35, unburnt. The incident caused national media coverage and a significant impact upon the local residents and businesses. A concurrent Garda investigation was also carried out. No learning was identified from this incident. Fire at 2 Donore Road, Dublin 19/12/2009 Bord Gáis responded to a fire adjacent to a Decorative Flame Effect gas fire that had been left unsupervised. The subsequent investigation identified that the fire, installed c.1997, had never been serviced and corrosion to three rivets had allowed hot combustion gases to exit the fire adjacent to combustible materials. No issues were identified with the manufacture or installation of 20 P age

21 the fire. There were no injuries to the property occupants. This incident illustrates the importance of regular and frequent servicing of gas appliances. Boiler Fire at 11 Milltown Drive, Churchtown, Dublin 18/12/2009 The fire at the boiler caused broken windows, smoke and heat damage around the boiler and on the first floor landing. Investigation identified that the boiler had been partially enclosed by a wooden partition. The flueways of the boiler were heavily sooted causing the hot combustion gases to exit through air intake openings at the side of the boiler casing, directly onto the flammable wooden partition. Interviews with the property owner identified that the boiler had been serviced some weeks prior to the incident. An investigation by the Register of Gas Installers of Ireland is continuing. Incident Review The CER also supported the National Consumer Agency (NCA) following two fatal incidents in Macroom (21/11/2008) and Glenties (24/09/2009) involving Liquefied Petroleum Gas cooker grills. The Safety Division supported extensive testing of appliances and a subsequent recall and modification strategy for the appliances identified. The modification was to amend the full door seal fitted on the cooker grill. This program is still progressing with more than 55% of all identified appliances being modified or scrapped. Also, following a CER review and a campaign by 21 P age

22 Bord Gáis Networks, customers were warned of the potential risk of storing wheeled bins and waste near to gas installations, following a number of malicious fires. Since implementation there has been a significant reduction in the frequency of these fires. Performance against Safety Objectives: 2009 Key Safety Objective 1: Minimising the Loss of Containment Gas undertakings are required to demonstrate that they have suitable management systems and procedures in place for managing the risks that lead to loss of gas containment events occurring. Within the scope of this objective are: Gas escapes reported by the public. Damage to the gas transmission (high pressure) and distribution systems (lower pressure). Gas entry into buildings. Surveillance of works near pipelines. Corrosion protection and prevention. Gas Escape Reports Public reported gas escapes have gradually reduced over the last three years, and continue to follow seasonal trends. Gas escapes frequencies are traditionally higher during cold periods due to elevated mains pressures and the increased use of gas. Outside gas escapes reduced by around 10% on 2008 and internal escapes within customer s premises reduced by around 5%. 22 P age

23 Breakdown of Public Reported Escapes , Q1 09 Q2 09 Q3 09 Q4 External No leak detected Internal Figure 3: Public Reported Gas Escape Frequencies for 2009 Third Party Damage There were no instances of third party damage to the gas transmission system during On the distribution system there were 682 instances of damage, a reduction of 39% on the previous year. Emphasis has been placed on hire companies and local authorities to develop a clearer understanding of the appropriate methods to adopt to prevent damage to buried gas infrastructure. Distribution Third Party Damages Breakdown Q1 09 Q2 09 Q3 09 Q4 PE Mains PE Services P age Figure 4: Third Party Damage Frequencies by Supply Pipe Type 2009

24 Gas Entry into Buildings There were no reported instances of gas entry into buildings from the Cast Iron gas network. This indicator was developed to monitor the Cast Iron distribution system, prone to fracture causing potential gas ingress into properties. The Cast Iron mains system has now been fully replaced with plastic piping systems. Pipeline Surveillance The high pressure gas transmission system, constructed from high quality, welded steel, has strict controls regarding third party works operating within close proximity. To avoid damage to pipelines or their protective coatings, Bord Gáis Networks maintain a surveillance programme with foot, vehicular and aerial surveys. During 2009 these activities identified and addressed 30 instances of such third party works. The CER identified a recurrent issue with respect to agricultural drainage works, and so BGN will issue third party damage prevention guidelines to all landowners with pipeline way leaves on their property during Breakdown of Transmission Related Encroachment Events Q1 09 Q2 09 Q3 09 Q4 09 Aerial Survey Encroachments/Event Ground Patrol Encroachments/Events Figure 5: Works identified near pipelines during P age

25 Pipeline Corrosion Protection Bord Gáis Networks use a number of Cathodic Protection (CP) systems to prevent pipelines from corroding and identify locations where pipeline coatings are breached or deteriorating. Previously CP performance was monitored manually requiring field based staff to visit sites and take readings. During 2009 Bord Gáis Networks have implemented a remote, electronic measurement system for all monitoring points. The performance during 2009 has not been fully established due to the introduction of a new continuous monitoring system. Transmission CP Tests Q1 09 Q2 09 Q3 09 Q4 09 Pipe to soil potentials planned Pipe to soil potentials completed Figure 6: Pipeline Cathodic Protection tests: planned vs actual 25 P age

26 Key Safety Objective 2: Maintaining Safe System Operating Pressure Gas undertakings are required to demonstrate that they have suitable management systems in place for managing the risks that can result in dangerously high or low gas operating pressure in the pipeline system(s). Within the scope of this objective are: Gas Outages Pressure Management and Control Gas Outages There were no gas outages on the transmission system during There were 9 reported outages on the distribution system. This represented a reduction on this frequency during 2007 (15) & 2008 (10). The prime cause of outages is third party damage. All outages during 2009 affected less than 100 customers. Bord Gáis Networks have developed a new advice booklet issued to third parties and are working with local authorities and plant hire companies to improve wider industry awareness. No. of Unplanned Dist. Outages by no. of customers Q1 09 Q2 09 Q3 09 Q Figure 7: Unplanned Distribution Outages P age

27 System Pressure Management Bord Gáis Networks operates a Supervisory Control and Data Acquisition (SCADA) system, which monitors system pressures and alarms when defined parameters are exceeded. There were no issues identified with the gas transmission system during There were 43 alarms for over/under pressure events on the distribution system, indicating an increase on levels experienced during 2007/8. These alarms may indicate a number of causes from a pressure fluctuation requiring no operational intervention to a gas outage. The increase during 2009 was largely due to software issues and new high demand supplies being added. This gives a false reading as only the immediate pipe system experiences a pressure drop. Frequency of occurence Frequency of System Pressure Drops Q1 09 Q2 09 Q3 09 Q4 09 Dist Trans Figure 8: Frequency of system pressure drops on the distribution system 27 P age

28 Key Safety Objective 3: Minimising the risk of injecting gas of non conforming quality Gas emergency incidents can arise due to gas of inappropriate quality being injected into the system and, as such, gas undertakings are required to demonstrate that they have suitable management systems in place for gas quality monitoring and managing the risks associated with the quality of gas that is injected into the system. The KPIs for this objective are: Odorant; and Gas Quality. Odorant Management In order to identify uncontrolled leaking gas, gas has an odour added to, which must be maintained within prescribed limits to be detected by the human nose. There were three noncompliant test results identified during This was a significant improvement on 20 identified during Most of these issues were associated with new pipelines with minimal or no flow, where the odorant falls out of the gas stream. This requires local injection to rebalance the levels of odorant. Gas Quality Ensuring gas quality remains within a prescribed range is critical to ensure that gas supply remains safe. An example would be where the heat value (Calorific Value) fluctuates causing an increased risk of carbon monoxide at the appliance. There were no issues identified with gas quality during P age

29 Safety Objective 4: Providing an Efficient and Coordinated Response to Gas Emergencies This Objective 4 states: Gas emergency events occur due to insufficient supplies into the network or a transportation constraint, including the actions of third parties. Gaslink is required to demonstrate that it has suitable arrangements in place for: (i) managing the response to localised gas emergencies; and (ii) undertaking the role of National Gas Emergency Manager during network gas emergencies. Additionally, all gas undertakings are required to demonstrate that they have suitable arrangements in place for responding to the requirements of the National Gas Emergency Manager in the event of large scale network gas emergencies occurring. The KPIs for this regulatory objective, which are discussed in Sections to 4.4.2, are: Gas Supply Emergencies; and Public Reported Escapes. Gas Supply Emergencies There were no gas supply emergencies during 2009 that required initiation of the National Gas Emergency Plan (NGEP). This plan was recently developed and authorised by the CER, and outlines the management principles for addressing a large scale gas supply emergency affecting gas supplies and electricity generation. Bord Gáis Networks undertook two exercises during the year; the first focussed on crisis management of a combined transmission and distribution emergency; the second was a simulated site based exercise involving the loss of supply to Dundalk and approx. 5,000 customers. Public reported Gas Escapes Bord Gáis are required to respond to all reported escapes of gas within 1 hour. There were 20,332 Public Reported Escapes in 2009 with 17 responded to outside of the 1 hour response criterion, making the response 99.92% compliant. The majority of these late arrivals were due to adverse 29 P age

30 weather conditions, particularly flooding and snow which may impede the response speed. Bord Gáis are required to respond to all gas escapes within 1 hour where possible. % Public Reported Escapes Attended < 1 Hour % 80.00% 99.92% % % 99.81% 60.00% 40.00% 20.00% 0.00% 09 Q1 09 Q2 09 Q3 09 Q4 Figure 9: Gas Escape Response Efficiency by quarter P age

31 Safety Objective 5: Minimising the Safety Risks Associated with the Utilisation of Gas Regulatory Objective 5 states: The key aim of this regime is that all categories of gas works designated by the Commission are only undertaken by competent gas installers who are registered, and subject to ongoing regulation and inspection, by the GSSB appointed by the Commission. The connection and re connection of customers installations to the gas supply network and the servicing of such installations are important safety risk issues that will be addressed within the scope of this objective. Customer education and safety awareness is an important part of this gas safety objective as discussed in key objective 6. The KPIs for this regulatory objective are: Registered Gas Installers and the Regulatory Scheme; Installation Statistics; Meters; Carbon Monoxide; Disconnections; and Incidents (Downstream of the meter). Registered Gas Installers and the Regulatory Scheme The CER embarked on an extensive promotional campaign during the implementation of the Gas Safety Supervisory Body which included national and local press, communication to industry parties and Installer Road Shows. The number registered on the scheme by the end of 2009 was 2,667 Registered Gas Installers. The scheme allowed for trainee, provisional and full membership categories, with the provisional membership category being phased out over the space of the year through training and development requirements. The competence of individual installers is 31 P age

32 affirmed not only at entry level to the scheme, but also through an ongoing inspection process which began when the requirement for registration became mandatory in June The inspectors codify their work with respect to the level of risk observed, and remedial actions are in accordance with the level of finding. During the two quarters only one severe defect was identified, associated with the incident at 11 Milltown Drive, Churchtown, Dublin. Once this defect was identified, the Registered Gas Installer involved was automatically subject to a Disciplinary Hearing. The outcome of that hearing resulted in the Registered Gas Installer requiring further inspection by the RGII, the cost of which will be borne by the Registered Gas Installer. Although the data set is still in its infancy, early indications confirm a higher incidence of faults with provisional members and a high rate of faults on industrial/commercial works Number of RGIs by Membership Class Q1 09 Q2 09 Q3 09 Q4 09 Trainee Provisional Full Figure 10: Registered Gas Installers by Class of Membership P age

33 Installation Statistics When a Registered Gas Installer performs an item of work (new installation, replacement or servicing) a completion certificate should be completed and a copy returned to the GSSB. During the last 2 quarters of 2009 the RGII received 51,604 appliance servicing certificates, 1,283 appliance replacement certificates and 2,242 new gas installation certificates 1. It is anticipated that this figure will rise as installers grow accustomed to the new scheme. Internal gas escapes have reduced year on year since 2007, however hazards identified by Bord Gáis Networks when visiting properties has slightly increased. This statistical trend will be closely monitored to identify learning or performance improvements. Meters Meter performance is gauged by monitoring frequencies of faulty or tampered meters. During 2009 there were 55 reports of meter tampering. It is expected that this statistic will reduce with ongoing meter replacement, smart metering and continuing vigilance within Bord Gáis. Bord Gáis Networks identified 5,336 faulty meters during Issues regarding the ageing meter population are currently being assessed. Faults may include leaks, noise and reading inaccuracy No. of Tampered meters identified Q1 09 Q2 09 Q3 09 Q4 Figure 11: Numbers of tampered meters identified during P age

34 No. of Faulty or Leaky Meters identified Q1 09 Q2 09 Q3 09 Q4 Figure 12: Numbers of meter leaks or faults identified during 2009 Carbon Monoxide The predominant measures for Carbon Monoxide are largely applied to develop the public perception with respect to the dangers of Carbon Monoxide. The effectiveness of Carbon Monoxide campaigns are measured through customer surveys and customer safety enquiries. The Safety Division has developed a Carbon Monoxide strategy for the future. The purpose is to develop the scope, application and measurement of Carbon Monoxide related activities. Specifically, this strategy seeks to develop existing technologies including Carbon Monoxide alarms whilst increasing the scope of strategic influence to all fossil fuel types, including coal, oil, wood and LPG. Bord Gáis Networks provide a free Carbon Monoxide safety check service to customers who may have concerns regarding their gas installation, but with no cause to suspect immediate danger saw an increase of 30% in these enquires. Also during 2009 Ipsos MRBI conducted random interviews with a sample of 1,000 adults and determined that awareness of Carbon Monoxide dangers had risen by 4 points to 91%. 34 P age

35 Number of CO Safety Checks since Q1 08 Q2 08 Q3 08 Q4 09 Q1 09 Q2 09 Q3 Q4 CO Safety Checks Figure 13: Number of customer requested safety checks performed during 2009 Safety Disconnections Bord Gáis Networks carry out safety disconnections where it has been identified that an unsafe situation exists on a customer s gas installation. The frequency of these disconnections has reduced steadily from a high of 630 at the end of 2007 to 386 at the end of 2009, a 39% improvement. 35 P age

36 Total Number of Safety Disconnections (since '07) Q1 07 Q2 07 Q3 07 Q4 08 Q1 08 Q2 08 Q3 08 Q4 09 Q1 09 Q2 09 Q3 Q4 Safety Disconnections Figure 14: Bord Gáis Networks Safety Disconnections during 2009 Incidents Downstream of the Meter Analysis of the 3 incidents occurring on the customer s gas installation identified one failure due to a malicious act and 2 incidents arising from poor or absent appliance servicing. The current safety campaigns emphasise the need to service appliances regularly, and to only use a Registered Gas Installer. The programme for 2010 intends to further emphasise this message through TV, radio and written media. 36 P age

37 Breakdown of Incidents Downstream of the Meter Q1'07 Q2 '07 Q3 '07 Q4 '07 Q1 '08 Q2 '08 Q3 '08 Q4 '08 Q1 '09 Q2 '09 Q3 '09 Q4 '09 Type A Type B Type C Figure 15: Incidents occurring on the customer s side of the gas meter during 2009 Key to Incident Types Type A: Concerns an incident where loss of life has been experienced Type B: An incident where an injury has been sustained requiring overnight hospitalisation as a minimum Type C: An incident where property damage exceeds an estimated value of 6, P age

38 Safety Objective 6: Promoting Public Awareness of Gas Safety Regulatory Objective 6 states: Increasing the level of gas safety awareness amongst gas customers and the public generally and, in particular, educating on the dangers of carbon monoxide is an important aspect of the Commission s overall objective of promoting the safety of customers and the general public in respect of the use of gas. It will also be important that owners/occupiers of premises are aware of their responsibilities in respect to the maintenance of gas fittings downstream of the meter. The proposed gas safety framework places duties and obligations on both individual gas undertakings and the industry generally for the promotion of gas safety awareness. This will involve a combination of both individual and co ordinated safety promotional activities by undertakings. The currently identified KPIs for this regulatory objective are: BGN Emergency Number Calls Carbon Monoxide Reports and website visits Dial Before You Dig Calls RGII website visits Emergency Number Calls The frequency of calls to the number is indicative of the public awareness of the number and its function. The number of calls to this number was 75,632 with confirmed gas escapes in 27% of cases. During 2008 there were 53,514 calls with escapes confirmed in 35% of cases. The high degree of non emergency calls has been attributed to the emergency number being prominently displayed on bills and other literature and therefore confirms customer 38 P age

39 awareness; however Bord Gáis Networks intend to review this promotion to ensure that customers are aware of the purpose of the number. Annual Gas Safety Report Calls to Emergency Number Q1 09 Q2 09 Q3 09 Q4 Calls to Emergency Number Total PREs Figure 16: Frequency of enquiries to the BGN emergency number vs actual reported gas escapes Carbon Monoxide Calls and Website Activity Calls and website hits remained seasonal in nature and aligned to advertising bursts. There were 5,178 unique website visits and 2,487 calls to the Carbon Monoxide help number during P age

40 Number of Calls to CO Helpline and Vistis to CO Website Q1 09 Q2 09 Q3 09 Q4 CO Website Visits Calls to CO Number Figure 17: Numbers of CO Enquiries Dial Before You Dig The dial before you dig process is designed to provide third parties with safety advice and planning material before they excavate. The majority of enquiries regarded distribution pipe locations (90%) with a total of 5,270 enquiries received during Total number of Enquires to DBYD Number Q1 09 Q2 09 Q3 09 Q4 Figure 18: Plant location enquires to the dial before you dig line 40 P age