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91 The National Association of Pipeline Safety Representatives (NAPSR) cir- culated a questionnaire in November 2017, developed by the study com- mittee, to the member pipeline program managers responsible for safety regulation in the 50 states, the District of Columbia, and Puerto Rico. There were 50 respondents to the questionnaire. Notably, the extensive responses to the third question regarding the number of regulated liquefied petroleum gas (LPG) distribution systems enabled the committee to draw useful insights for the study. For the other questions, the variability in the responses proved a challenge for analysis. The responses to the question- naire from the pipeline safety program managers are available in the public access file for the study. QUESTIONNAIRE 1. What are the most common regulatory violations found in inspec- tions of LPG pipeline systems serving 99 or fewer customers? 2. How often are enforcement actions taken against facilities (by jurisdiction status and state)? What relief is sought (i.e., citations, civil penalties, injunctions)? 3. How many jurisdictional systems (as defined by 49 CFR Part 192) exist in your state or are under your safety jurisdiction? a. Number of jurisdictional systems: b. Number of systems serving 100 or more customers: c. Number of systems serving 50â99 customers: APPENDIX A Questionnaire to State Pipeline Safety Program Managers on the Regulation of Liquefied Petroleum Gas Distribution Systems
92 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS d. Number of systems serving 10â49 customers: e. Number of systems serving fewer than 10 customers: 4. How many jurisdictional systems are inspected annually? 5. How often are jurisdictional systems inspected? 6. How many non-jurisdictional systems exist in your state (estimate if not known)? 7. How much is expended on enforcement of jurisdictional LPG pipe- line facilities? 8. If your agency uses resources to enforce non-jurisdictional LPG pipeline facilities, how much would you estimate is expended on enforcement? Is this expenditure part of the current budget for enforcement of jurisdictional systems? 9. What are the most common types of failure for propane gas sys- tems? Please identify the five most common failure modes. 10. To the best of your understanding, in a scenario where the thresh- old for qualifying as a non-jurisdictional system were raised to 99, which public agency would become the authority having jurisdic- tion for these systems with less than 100 customers? 11. When inspecting a facility under your jurisdiction, what documents are facilities expected to maintain compliance with (U.S. DOT; National Fire Protection Association, NFPA). Please note which version of the document; e.g., NFPA 58 2004 versus NFPA 58 2017, NFPA 59. 12. Are there specific changes to the operation/maintenance require- ments in Part 192 that the regulators should consider as an alterna- tive to exempting the facilities from Part 192? 13. Would you support the creation of a separate, streamlined inspec- tion program for small LPG facilities? If so, in your estimation, what features must it include to assure safety outcomes consistent with current safety trends and why? 14. The NFPA develops its standards using a well-documented process. Do you have any general governance concerns regarding the pro- cess used in the creation or modification of past or current editions of the NFPA 58 standard?
