the voice and choice of public gas
Excess Flow Valves for Multi-Family and Commercial Services Final Rule John Erickson, P.E.
American Public Gas Association
Excess Flow Valves
the voice and choice of public gas
Excess Flow Valves
the voice and choice of public gas
• EFVs were controversial in the 60’s, 70’s, 80’s, 90’s and 00’s due to false closure experiences and concerns • After February 3, 1999 operators were required to notify customers about EFVs for new and replaced single residential services • After February 12, 2010 operators were required to install EFVs on such services • 10.5 million EFVs in service 12/31/2015
Excess Flow Valves
the voice and choice of public gas
• Current rules require EFVs on new and replaced service lines to single residences (with a few exceptions) • In 2011, Congress required PHMSA to consider extending the requirement to new and replaced multi-family, commercial, industrial services • PHMSA convened a group of industry, manufacturers, regulators and public to advise it
Excess Flow Valves
the voice and choice of public gas
• Rule as proposed July 21, 2015 • EFVs will be required on new and replaced services to: – Single family residences (SFR)(current rule) – Branched services to 2 SFRs – Multi-family residences with loads not exceeding 1,000 SCFH per service* – Commercial customers served by a single service line with a known load not exceeding 1,000 SCFH* *Based on installed meter capacity
Keeps Existing Exceptions the voice and choice of public gas
• The service line sometimes operates below 10 psig; • Service experiences contaminants in the gas stream that could interfere with the EFV’s operation or cause loss of service; • EFV could interfere with necessary operation or maintenance activities; or • An EFV meeting performance standards in §192.381 is not commercially available to the operator.
Customer Notification
the voice and choice of public gas
• Operators must notify customers within 90 days of the customer “first receiving gas at a particular location” of their right to request an EFV • Existing service line customers, who desire an EFV on service lines not exceeding 1,000 SFCH may request an EFV be installed on their service line • If requested, operator must install the EFV at a mutually agreeable date
Cost Recovery
the voice and choice of public gas
• “The appropriate State regulatory agency determines [to] whom and/or how the costs of the requested EFVs are distributed.” • APGA commented that most distribution operators’ rates are approved by local governing bodies, not state agencies
Curb Valves
the voice and choice of public gas
• The operator must install a manual service line shut-off valve for any new or replaced service line, with installed meter capacity exceeding 1,000 SCFH. • Manual service line shut-off valve is located near the service main or a common source of supply that is accessible to first responders and operator personnel to manually shut off gas flow to the service line in the event of an emergency.
Final Rule
the voice and choice of public gas
• Published October 14, 2016 • Effective April 14, 2017 • No change to EFV installation mandate on new and replaced: – Single family residences (SFR)(current rule) – Branched services to 2 SFRs – Multi-family residences with loads not exceeding 1,000 SCFH per service* – Commercial customers served by a single service line with a known load not exceeding 1,000 SCFH*
Customer Notification
the voice and choice of public gas
• Operators must provide written or electronic notification to customers not meeting any of the 4 exceptions of their right to request the installation of an EFV. • Electronic notification can include emails, Web site postings, and e-billing notices. • Rule does not require customers to be renotified annually or at any other timeframe • An operator must make a copy of the notice or notices currently in use available during PHMSA or State inspections
Customer Notification
the voice and choice of public gas
• Notification must include: – Potential benefits of an EFV – Description of EFV installation and replacement costs – That, unless the service meets one of the 4 exceptions, operator must install the EFV at a mutually agreeable date
• Operators of master-meter systems and small LPG operators may post a general notification in a prominent location frequented by customers.
Cost Recovery
the voice and choice of public gas
• “The appropriate State regulatory agency determines whom and/or how the costs of the requested EFVs are distributed.” • Now “The operator’s rate-setter determines how and to whom the costs of the requested EFVs are distributed” • Options for cost recovery can be discussed in the roundtables
Curb Valves
the voice and choice of public gas
• The operator must install a manual service line shut-off valve or an EFV for any new or replaced service line, with installed meter capacity exceeding 1,000 SCFH. • “Manual service line shut-off valves for any new or replaced service line must be installed in such a way as to allow accessibility during emergencies.”
Maintenance of curb valves the voice and choice of public gas
• “Manual service shut-off valves installed under this section are subject to regular scheduled maintenance, as documented by the operator and consistent with the valve manufacturer’s specification.” • Not the annual inspection and maintenance required by 192.747
the voice and choice of public gas
• Questions will be addressed in the roundtables • People at front tables remain here • People at back tables proceed to amphitheater • Each roundtable will be repeated in each room