Program Information
What is a natural gas pipeline system?
The U.S. has a national pipeline network of about three million miles of mainline and other pipeline infrastructure which links natural gas production areas and storage facilities with consumers. Interstate natural gas pipelines operate and transport natural gas across state borders. Intrastate natural gas pipelines operate and transport natural gas within a state border. When natural gas arrives at the locations where it will be used (usually through large pipelines), it flows into smaller diameter pipelines called mains and then into smaller service lines that go directly to homes or buildings.
Colorado holds three percent of the nation’s transmission miles, four percent of the nation’s gathering miles, and 30 percent of the nation’s distribution miles.
Who's involved in ensuring the safety of Colorado’s natural gas pipeline system?
The safety of Colorado’s natural gas pipeline system involves several organizations, including private operators (e.g. utility companies).
Federal:
Federal Pipeline & Hazardous Materials Safety Administration (PHMSA): Responsible for issuing rules for operators and overseeing the state programs. By law (49 USC 60107) PHMSA is authorized to develop a Federal/State partnership, which allows PHMSA to authorize and administer the State Pipeline Safety Program under 49 USC 60105 and/or 60106.
State:
Colorado Public Utilities Commission (PUC): Responsible for inspecting and monitoring intrastate gas pipeline system operators under the review of PHMSA, adopting and incorporating federal requirements into state rules and regulations, and determining the final compliance action in response to probable violations. The commission also reviews, approves and tracks safety investments made by utility companies.
Energy and Carbon Management Commission (ECMC) formerly Colorado Oil and Gas Commission (COGCC): Regulates flowlines and wells.
Colorado Department of Labor and Employment (CDLE) Division of Oil and Public Safety (OPS) - Administers the Damage Prevention Program for oil and gas wells.
Operators:
Gas Pipeline Operators are responsible for corrosion control, operations and maintenance, public awareness, emergency response, operator qualification, damage prevention, and building and maintaining a safe pipeline system.
What is the PUC’s specific role and jurisdiction?
The PUC has two primary responsibilities with pipeline safety.
It’s the official “State Delegate” for PHMSA, which manages the Pipeline Safety Program. Duties consist of operator inspections, compliance and enforcement, safety programs, accident investigations, design, testing, and construction (DTC) inspections, and record maintenance and reporting. The PUC also receives and investigates complaints and issues notice of hearings for all alleged violations, petitions, hearings, investigations, and proceedings. This authority is exercised through the Pipeline Safety Program section of the PUC.
The PUC also reviews, approves and facilitates investments in pipeline safety on the part of pipeline operators. In the last 10 years utility companies have made significant safety investments, which the PUC has ensured are prioritized over non-safety related work.
What part of the natural gas pipeline system does the PUC regulate?
The natural gas system involves the flow of natural gas from wells to private homes and buildings. The PUC only has authority over part of the natural gas system as indicated below (see green checkmark) and limited to intrastate pipelines.
The PUC does not have jurisdiction over pipelines not engaged in transport (i.e. pipelines directly associated with gas production, and gas piping within a home or business which is the responsibility of the customer and is regulated by the city or county building codes).
It also does not oversee interstate pipelines - those used to transport hazardous gas across state lines, liquids such as petroleum, petroleum products, anhydrous ammonia, ethanol or other non-petroleum fuel, biofuel, or a liquid which is flammable, toxic or would be harmful to the environment if released in significant quantities.
How does the PUC ensure natural gas pipelines are safe?
The PUC inspects and audits all the pipeline operators under the jurisdiction of the 49 USC 60105 certification. The PUC’s role is preventative in nature, with a goal of zero gas escaping the pipeline system in the State of Colorado. Preventing any kind of release or incident/event is performed by inspecting operator construction activities (which include new construction and repairs) and auditing all processes and procedures that are specific to the operator and to the system.
Investigation of releases or incidents/events and enforcement activities are reactive and not preventative in nature. However, these investigations can determine a systemic issue within an operator’s process and procedure that might not be found from a typical inspection or audit, thereby preventing future incidents.
Who inspects the pipelines?
The PUC has 14-full-time staff, including seven full-time inspectors, three part-time inspectors, one Geographic Information System Mapping (GIS) expert, and program administrator. Collectively the team has 167 years of experience in the natural gas industry, with over 260 years of technical experience.
What’s involved with an Inspection and how often are they conducted?
There are multiple types of inspections conducted by the PUC and each has a different series of steps:
Records Inspections - Examine an operator’s program-wide plans (drug, alcohol, public awareness, control room management, and damage prevention programs, etc). These are generally performed as record reviews and do not require a field visit.
Field inspections - conducted on-site at various stages of the system, including design, construction and maintenance.
Master meter and Liquid Petroleum Gas Operator (MMO/LPG) inspections could include field and record or just record inspections, depending on the compliance status.
Frequency of inspections occurs at intervals and based on state and federal guidelines to ensure a successful program and safe pipeline system. They can range from immediate responses to an incident to every five years of the operators Qualification Plan.
What happens when a complaint is filed or the PUC learns of an accident?
For incidents and events there is a federal system and a state system for notifications. Operators are trained on which system to call, depending on the event.
A call to the state PUC Emergency Reporting Line is required if an incident or event meets the following criteria. The Pipeline Safety Program Emergency Reporting line is monitored 24/7 by a designated, on-call inspector.
A call to the state PUC Emergency Reporting Line is required if an incident or event meets the following criteria. The Pipeline Safety Program Emergency Reporting line is monitored 24/7 by a designated, on-call inspector.
1. Evacuation of 50 or more people
2. Closure of all lanes in either direction of a roadway or railroad
3. Evacuation of 4 or more residential structures
4. Service outage of 100 or more customers
5. Active soil vapor extraction for 48 hours or more
6. Exceedance of Maximum Allowable Operating Pressure
7. Courtesy notification, defined by the operator
A call to the federal national response center is required if an incident or event meets the following criteria. Every call to the NRC results in an “NRC Report”.
1. Death or injury
2. Damage meeting or exceeding $129,300
3. Release of certain quantity of natural gas (3MM CF) or more
4. Significant event as defined by the operator
NRC Reports are continuously monitored by the Pipeline Safety Program Manager, Team Leads, and on-call inspectors. If an NRC Report is determined to be within the jurisdiction of the PUC, the PSP team works with PHMSA investigators to perform investigations. The person on-call reviews and logs every call, determines jurisdiction and if a site visit is necessary.
Complaints are also received to Pipeline Safety Program through the DORA general email, Pipeline Safety Program general email, emergency reporting line, and directly to inspectors. All logged incidents, events, and complaints are reviewed by the investigations team.
What authority does the PUC have to fine natural gas operators? How large can these fines be?
PUC has authority to issue civil penalties based on Section 40-7-117, C.R.S.. Fines are capped at $200,000 per violation and the aggregate amount of penalties shall not exceed $2 million. Additionally, a minimum penalty of $5,000 was set by recent state legislation.
Why was the PUC’s pipeline safety program audited?
The audit was initiated by a member of the state legislature, which is the typical process for most audits conducted by the Office of the State Auditor (OSA). OSA initiated a performance audit in July of 2022.
To see the full report, recommendations and corrective plan of action, click here.
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