Industry becoming more comfortable with excess flow valves.
EFVs are inexpensive to install when a service line is first installed or later replaced, but significantly more expensive to retrofit on an existing service or replace if the valve fails or a customer installs gas-burning equipment that requires more gas than the EFV will allow through the service line.
For 16 years, I was the point man at the American Gas Association (AGA), pushing back against what we saw as dubious claims of EFV benefits and dismissal of concerns about potential EFV costs.
Here it is 34 years later. I'm nearing retirement, and EFVs are still a hot topic. Today, however, EFVs are not nearly as controversial as they were back in 1981. In 1981, some utilities that had been early adopters of EFVs in the '60s and '70s had experienced so many unwanted EFV closures--EFVs closing under normal conditions--that they undertook programs to proactively remove EFVs from their systems.
Other utilities, most notably Bay State Gas (now part of NiSource) and East Ohio Gas, had good experience with EFVs and continued to install them on most new and replaced service lines. Since 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has required all utilities to install EFVs on new and replaced service lines serving singlefamily residences.
By year-end 2014, over 9 million EFVs were in service and over 800,000 new EFVs were being installed each year. When EFVs are discussed at APGA committee meetings, many members speak positively, reporting that EFVs reliably close when a service line is severed and that unwanted closures are rare.
As a result, PHMSA's latest proposal to extend mandatory EFV installation to larger service lines is not generating the level of emotion as have previous EFV rulemakings.
On July 15, 2015 PHMSA proposed requiring utilities to install EFVs on new and replaced residential and commercial service lines if the meter capacity on the line is 1,000 cubic feet per hour (cfh) or less. On new and replaced service lines with meter capacities over 1,000 cfh, the utility would be required to install a manually operated "curb valve."
Utilities would have to notify customers about EFVs. If the customer requests, an EFV would also have to be installed on the existing service line. As mentioned earlier, the cost of retrofitting and EFV on an existing service can be significant, possibly exceeding the customer's total annual gas bill. PHMSA's proposal leaves it up to the utility and its rate-approving authority to determine whether the cost of retrofitting an EFV should be paid by the customer requesting the EFV or shared among all customers.
Because of the experience gained with EFVs over the past few years, the industry is more comfortable with PHMSA's proposed EFV installation requirements than it has been in past EFV rulemakings. In fact, both APGA's and AGA's comments on the Advance Notice of Proposed Rulemaking suggested PHMSA mandate EFV installation on new and renewed residential and commercial services up to 1,000 cfh. Some utilities have been voluntarily installing EFVs on such service lines for years.
The customer notification and choice proposal is more problematic. APGA, in its comments on the proposed rule, sought clarification on just who is the "customer" that the utility must notify.
Is it the property owner, the person paying the gas bill, the person consuming the gas or someone else? PHMSA stated in the preamble to the proposed rule that customer notification can be satisfied by a message included with a customer's gas bill, suggesting the "customer." APGA did not oppose the proposed customer notification and choice requirement. Instead, we suggested ways that PHMSA can make it easier for utilities to comply.
For example, PHMSA's proposal requires utilities to notify customers "within 90 days of the customer first receiving gas at a particular location." That would require a utility to modify its billing system so a bill insert could be added to just certain customers' bills. APGA suggested as an alternative that utilities could notify all customers annually and accomplish PHMSA's intent at a lower cost.
There are concerns with the curb-valve proposal as well. PHMSA proposed that each curb valve installed under the rule be "accessible to first responders." Allowing non-utility personnel without proper training to operate an underground utility valve is dangerous. Quoting the Pipeline Emergencies firefighter training program, developed with PHMSA funding:
"Emergency-responders should NEVER attempt to isolate any pipeline valves on large-diameter transmission or distribution lines unless under the direction of pipeline operations personnel. Failure to do so may actually create additional problems that are worse than the original event."
PHMSA's regulatory impact analysis on the curb-valve proposal is also questionable. PHMSA assumes closing a curb valve could have prevented 90% of the fatalities, injuries and property loss in 13 reportable incidents that occurred between 2005 and 2011. However, in a gas incident, deaths and injuries usually occur in the first few seconds, long before anyone could close a curb valve.
There is sufficient information in the incident reports for many of these 13 incidents to rule out that closing a curb valve would have prevented any of the adverse consequences. In one incident, the incident report stated that the "driver died at the scene due to injuries sustained in a car crash."
In another report, the narrative stated that utility personnel responded and "shut off the service line at the curb." [The 13 incident reports cited by PHMSA actually make a strong case that requiring curb valves on service lines will have negligible safety benefits.]
While APGA questions PHMSA's regulatory analysis, we accepted the proposed curb-valve installation requirement with three caveats:
The final rule should not require that curb valves be accessible to non-utility personnel.
PHMSA should reaffirm its longstanding position that curb valves are not "valves required in an emergency," so do not require annual inspection under 129.747.
The rule should allow utilities to install an EFV on a service line in lieu of a curb valve. Although most operators have little or no experience installing EFVs with trip points greater than 1,000 cfh, such EFVs are available and such a provision in the rule could encourage utilities to gain experience with larger EFVs.
EFVs are just one tool to address the risk posed by excavation damage to service lines. Damage prevention programs, 811, public awareness and other programs that aim to prevent the service line from being damaged are the first line of defense.
On a personal note, Mike Israni, PHMSA's project manager for this rulemaking, is retiring from PHMSA to spend full time doting on his grandchildren. Mike joined PHMSA in 1994 and his first project was the EFV customer notification rule. Now he's going out with another EFV rule.
It has been my pleasure to work with Mike on EFVs, DIMP and all the other pipeline safety issues he has handled for PHMSA for 21 years. His many friends in the industry wish him all the best.
By John Erickson, Vice President of Operations, American Public Gas Association