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Report of the Technical Regulator This is the annual report of the Technical Regulator under the Gas Act 1997. It describes the operations of the Technical Regulator for the financial year 2014/15 as required by sections 14 of the Gas Act 1997. This section requires the minister to cause a copy of the report to be laid before both Houses of Parliament.
The Technical Regulator is a statutory office established by Section 7 of the Gas Act 1997. Robert Faunt has held this office since he was appointed as the Technical Regulator on 28 February 2003.
Technical Regulator: Robert Faunt
Address: Level 8, ANZ Building 11 Waymouth Street Adelaide 5000
Postal Address: GPO Box 320 Adelaide SA 5001
Telephone: (08) 8226 5500
Facsimile: (08) 8226 5529
Office Hours: 9 am to 5 pm, Monday to Friday (except public holidays)
Website: www.sa.gov.au/otr
Email: [email protected]
ISSN: 1832-8687
Front Cover Photos: Top: The city gate odorising, gas metering and pressure reduction compound that feeds natural gas to the Port Pirie Township and local industries.
Middle: Type B testing of a new hot water boiler in the plant room of a building
Bottom: Port Bonython LP gas production facility
Note: All photographs in this report have been used with the permission of the relevant provider.
Annual Report of the Technical Regulator
Electricity 2013/14
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Preface This report covers the Technical Regulator’s operations under the Gas Act 1997 for the financial year ending 30 June 2015.
Gas Act 1997
Section 3 of the Gas Act 1997 states that:
“The objects of this Act are—
(a) to promote efficiency and competition in the gas supply industry; and
(b) to promote the establishment and maintenance of a safe and efficient system of gas distribution and supply; and
(c) to establish and enforce proper standards of safety, reliability and quality in the gas supply industry; and
(d) to establish and enforce proper safety and technical standards for gas installations and appliances; and
(e) to protect the interests of consumers of gas.”
The Technical Regulator is established by section 7 of the Act. Section 8 of the Act states that:
“The Technical Regulator has the following functions:
(b) the monitoring and regulation of safety and technical standards in the gas supply industry; and
(c) the monitoring and regulation of safety and technical standards with respect to gas installations; and
(da) the provision of advice in relation to safety or technical standards in the gas supply industry to the Commission at the Commission’s request; and
(e) any other functions assigned to the Technical Regulator under this Act.”
The Act was amended by the advent of the Energy Products (Safety and Efficiency) Act 2000 in May 2012. This Act makes provisions relating to safety, performance, energy efficiency and energy labelling of products powered by electricity, gas or other energy sources.
The Technical Regulator advises the Minister for Energy on gas emergency management and related issues. In addition, the Technical Regulator provides input and is involved in a range of activities in liaison with the gas industry and other Government agencies. The Technical Regulator’s operations in relation to these functions are dealt with in various sections of this report.
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Content
Report of the Technical Regulator i
Preface ii
Content iii
Technical Regulator’s Commentary 1
The Office of the Technical Regulator 3
Section 1: Overview of the Natural Gas Industry in SA 4
Section 2: SA Natural Gas Supply 5 2.1. Natural Gas Infrastructure 7 2.2. Safety of Natural Gas Infrastructure 7 2.2.1. Safety, reliability, maintenance and technical management plan (SRMTMP) 7 2.2.2. Gas Measurement Management Plan (GMMP) 8 2.2.3. Auditing for Safety and Technical Compliance 9 2.2.4. Gas Incidents 10 2.2.5. Third Party Damage 12 2.2.6. Gas Leak Public Reports 13 2.2.7. Leakage surveys 14 2.2.8. Unaccounted for Gas (UAFG) and Mains Replacement Plan (MRP) 14 2.3. Safety of Liquefied Petroleum Gas (LP gas) Distribution Networks 16 2.3.1. Auditing for Safety and Technical Compliance 17 2.3.2. Incident Reporting 18
Section 3: Natural Gas and LP gas Installations 19 3.1. Responsibilities 19 3.2. Residential and Light Commercial Gas Installations 19 3.3. Industrial and Large Commercial Gas Installations 19 3.4. Auditing for Compliance 22 3.4.1. Proactive Audits 22 3.4.2. Mobile installations in Recreational Vehicles 24 3.4.3. Temporary kitchens at outside events 25 3.4.4. Audits of Permanent Gas Installations at Tourist and Caravan Parks 27 3.4.5. Effect Burners used in Public Events or Productions 28 3.4.6. Installation Audit Results 28 3.4.7. Enforcement Activities for Non-compliant Gas Installations 29 3.4.8. Referrals to Consumer Business Service (CBS) 30 3.5. Gas Incidents – Installations 30 3.6. Gas Certificates of Compliance (GCC) 32 3.7. Communication and Education 33 3.7.1. Industry Liaison and Support 33 3.7.2. Technical Presentations 33 3.7.3. Assistance with the Development of Technical Training Courses 33 3.7.4. Standard Committee Representation – Formulation of Standards 33 3.7.5. New Gas Installation Standard called up by the Gas Act 34
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Section 4: Natural Gas and LP gas Appliances 35 4.1. Gas Appliance Certification 35 4.2. Appliance and Component Recalls and Safety Notices 35 4.3. Small mobile LP gas appliances 36
Section 5: Consumer Safety Awareness 38 5.1. Gas Retailers’ Safety Awareness Plans (SAP) 38 5.1.1. Continuous Safety Promotion 38 5.1.2. The Technical Regulator Website 39 5.2. Gas Consumer Safety Survey 40
Section 6: Gas Supply Emergency Management 42
Section 7: Regulatory Coordination 44 7.1. Safety and Technical Standards 44 7.2. Committee Representation 44 7.2.1. AG-006, Gas Installation Committee (AS 5601) 44 7.2.2. AG-001, Gas Appliances Committee 44 7.2.3. AG-008, Gas Distribution Committee (AS/NZS 4645) 45 7.2.4. AG-010, Natural Gas Quality Specifications Committee (AS 4564) 45 7.2.5. Gas Technical Regulators Committee (GTRC) 46 7.2.6. Other Committees, Forums and Representation 46
Appendix 1. OTR Background 49 A1.1. OTR Organisational structure and Gas branch 49 A1.2. Technical Regulator’s activities and monitoring 50
Appendix 2. Certificate of Compliance 51
Appendix 3. Presentations 52
Appendix 4. Operating Statement 53
Appendix 5. Network Performance 2014/15 55
Appendix 6. Glossary and Abbreviations 60
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Technical Regulator’s Commentary The Technical Regulator carried out investigations, audits and other gas industry monitoring activities to help ensure that the South Australian public continues to receive a reliable and safe gas supply.
In the 2014/15 year, the major aspects of the Technical Regulator’s operations and administration were the following.
Gas Installation and Appliances – Incidents and Safety No gas related deaths were reported during the year but 15 gas related incidents involving injury or significant property damage were investigated.
There were 8,544 new connections to the natural gas distribution system. All new installations connected to the natural gas supply are subjected to a pre-connection safety check agreed to by the Technical Regulator. The safety check ensures the system is gas tight and that the installation and appliances comply with Australian Standards. The Technical Regulator monitors the effectiveness of this system by carrying out random audits.
The Technical Regulator proactively audited 87 industrial and commercial (I&C) installations and 1,091 residential and light commercial installations making a total of 1,178 audits.
Gas Appliance Online Activity The purchase of uncertified gas appliances continues as an important issue. The Technical Regulator continues to monitor the various internet auction sites with a view to eliminating the availability of uncertified gas appliances.
Safety of Gas Supply Audits of Australian Gas Networks (AGN), Origin Energy LPG and Environmental Land Services (Aust) Limited (ELS) satisfied the Technical Regulator that there are sound systems in place to ensure that risks to the community from the operation of natural gas and LP gas distribution networks are being managed to an acceptable level.
The Technical Regulator was pleased that the amount of Unaccounted for Gas (UAFG) from the AGN natural gas distribution networks decreased in 2014/15. AGN replaced approximately 266 km of old gas mains over the last 12 months.
Industry Communication and Education A total of 13 Industry Roadshows regarding gas safety were carried out in conjunction with the Plumbing Industry. All licensed gas workers and contractors in South Australia were invited to attend. In addition 18 presentations were given to industry stakeholders, i.e. consultants, registered training organisations (RTOs), Housing Industry and Association (HIA) event organisers and other Government Departments.
There were two editions of the industry newsletter Regulation Roundup (a general gas, electrical and plumbing information newsletter, sent to all licensed gas and electrical contractors and registered workers) issued in the 2014/15 period.
Public Safety Awareness and Safety Education The Technical Regulator conducts an annual public safety awareness campaign. This campaign included specific and general gas safety media releases, radio advertising and internet google word searching. The topics covered gas appliance safety, carbon monoxide awareness, the importance of using a licensed tradesperson and obtaining a Gas Certificate of Compliance for all gas installation work. The campaign continues to remind the public of the importance of reporting gas leaks.
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The Consumer Safety Survey for this year provided data that will help to improve the effectiveness of the Technical Regulator’s safety campaign.
Reliability of Gas Supply and Emergency Management There was one major gas supply interruption during 2014/15. This incident affected the supply of natural gas to both Port Pirie and Whyalla consumers for a period of approximately eight days. The Technical Regulator corresponded with all stakeholders and closely monitored and assisted with the situation. The Technical Regulator was positioned to implement temporary gas rationing should it have been required.
Australian Standards and Regulatory Committees The Technical Regulator provided expert technical input in the revision of key Australian Standards on gas installations and appliance requirements. The Technical Regulator also contributes to the development of safety standards across the gas sector by partaking in the activities of the Standard Australia’s Gas Sector Board.
The Technical Regulator regularly liaises with a large number of industry stakeholders through the Gas Technical Advisory Committee (GTAC). This group includes representatives from, relevant contractor groups, employee associations involved in the gas supply industry, local government and the gas distributors (natural gas and LP gas). GTAC meets twice yearly to provide advice to the Technical Regulator on any matter relating to his functions. The Technical Regulator is also represented on the Gas Technical Regulators Committee (GTRC), a group comprising Gas Technical Regulators from other states, territories and New Zealand. This group considers technical and policy issues relating to the gas industry with a view to ensuring consistency across the jurisdictions. GTRC’s primary purpose is to ensure that the Australian public continues to have a reliable and safe gas supply and associated appliances. The Technical Regulator also participated in the National Gas Emergency Response Advisory Committee (NGERAC).
Discharge of legislative responsibilities The Technical Regulator continued to perform its functions well during the financial year 2014/15. All legislative functions assigned to the Technical Regulator have been performed throughout the year within the resources allocated for this purpose. Analysis of resource efficiency indicates that the office is making good use of available resources, while servicing an increasing consumer base.
Rob Faunt, Technical Regulator
September 2015
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The Office of the Technical Regulator The Technical Regulator is supported by the Office of the Technical Regulator (OTR). It is separate from the gas supply and the gas contracting industries (privately-owned distribution and retail entities) that it regulates with respect to safety and technical matters. The OTR is a section comprising 47.8 full time equivalent employees within the Energy Markets and Programs Division of the Department of State Development (DSD). There are 8.6 full-time equivalent positions assigned to the gas Branch of the OTR with the administration, safety promotion and legal support functions shared with the electrical and plumbing branches of the OTR. The organisational structure of the OTR is shown in Appendix 1.1.
The Technical Regulator ensures the safety of the community by enforcing safety measures and standards that apply to gas infrastructure (distribution systems) and infrastructure operation, work on gas installations (consumer premises), gas appliances and installation operations. These safety and technical measures aim to minimise the risk from gas related activities to as low a level as is reasonably practicable. To fulfil this responsibility, the Technical Regulator carries out an extensive range of activities. These responsibilities and activities are discussed in detail in this report.
The Technical Regulator plays an important role in the development and monitoring of applicable national safety and technical Standards and Codes. The Technical Regulator also provides technical support and advice to the Minister for Energy during periods of gas supply shortages, and facilitates discussion with industry participants to achieve the best possible outcome for the state.
The regulation of gas networks is important to ensure that they are designed, installed, maintained and operated in a satisfactory manner. Gas pipelines are located under the streets and footpaths of metropolitan Adelaide and some regional centres and it is imperative that they operate safely. In addition, it is vital to end user safety that gas installations and appliances are designed, installed and operated in a satisfactory manner.
The flow chart in Appendix 1.2 summarises the activities through which the Technical Regulator fulfils his obligations under the Gas Act 1997 and Gas Regulations 2012, demonstrating the relationship with the gas supply chain as well as safety for gas appliances under the Energy Products (Safety and Efficiency) Act 2000.
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Section 1: Overview of the Natural Gas Industry in SA Natural gas was first introduced into South Australia in 1969 and it has grown in importance since then with approximately 32.5 PJ (Peta-Joules) delivered to the South Australian distribution network over the last 12 months. This network has now grown to serving 430,244 consumers. Typically commercial and residential consumers use natural gas for cooking, space and water heating. Industrial use includes processes such as car, cement and glass manufacturing and steel production.
The total amount of gas delivered into the South Australian market has reduced from approximately 91 PJs in 2013/14 to 82.4 PJs in 2014/15 and of that amount, 58% was consumed in generating electricity.
The structure of the South Australian natural gas industry is shown schematically in Figure 1-1 (the italicised text in Figure 1-1 denotes areas licensed and regulated outside the Technical Regulator under the Petroleum and Geothermal Energy Act 2000 and other legislation).
Retail
Production Transmission Distribution Installations and Storage GAS major pipelines GAS (streets) GAS (buildings)
Residential and Light Industrial Electricity Commercial Appliances Equipment Generators
Figure 1-1: Natural gas supply and utilisation in South Australia
Figure 1-2: Schematic of natural gas supply and use in South Australia
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Section 2: SA Natural Gas Supply In South Australia, natural gas is supplied from a number of sources and transported to its destinations in the various transmission pipelines as indicated in Figure 2-1 below.
Figure 2-1: Southern and eastern Australian gas fields and major pipelines
Of the total amount of gas supplied to the State for 2014/15, approximately 28% came from the Cooper Basin, 50% came from Victoria (Otway and Gippsland Basins and Iona storage facility), 22% came from South West Queensland (SWQ) via the QSN link and there was no gas supplied from the Limestone Coast. There are two major independent gas supply pipelines, the Moomba to Adelaide Pipeline (MAP) and the SEAGas pipeline. The pipelines independently deliver gas to the Adelaide metropolitan area thus providing a security of supply to the network and power generators in that region. There has generally been a concern regarding the single source of supply to both the Port Pirie and Wasleys laterals in the north, however, both of these laterals can now be feed from the SEAgas pipeline following the northern interconnect project. This was a joint venture project between Epic Energy South Australia and SEAgas and is located at the Pelican Point Power Station. This interconnection between the two transporters allows gas to travel north from Adelaide via the MAP and it commenced operation at the beginning of June 2015.
Total gas usage for SA since June 2013 (excludes Limestone Coast) 10000 9000 8000 7000 63% 6000 72% 57% 61% 5000 61% 66% 62% TJ 58% 50% 57% 67% 50% 49% 4000 3000 2000 1000 0 Jun- Jul-13 Aug- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- May- Jun- 13 13 13 13 13 13 14 14 14 14 14 14 percentage Total usage including power stations (TJ) Total Usage Power Stations Only
Figure 2-2: Past trend in the utilisation of gas in South Australia for 2013/14 (Gas to network versus gas to power generation)
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Figure 2-2 and Figure 2-3 clearly demonstrate that the majority of gas supplied to South Australia is being used in generating electricity. It is also noteworthy that the amount of gas consumed directly and in generating electricity is currently trending downwards.
Total gas usage for SA since June 2014 (excludes Limestone Coast) 10000 9000 8000 7000 64% 6000 5000 62% 64% 59% 64% 55% TJ 49% 61% 59% 50% 4000 58% 45% 45% 3000 2000 1000 0 Jun- Jul-14 Aug- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- May- Jun- 14 14 14 14 14 14 15 15 15 15 15 15 percentage Total usage including power stations (TJ) Total Usage Power Stations Only
Figure 2-3: Current trend in the utilisation of gas in South Australia for 2014/15 (Gas to network versus gas to power generation)
The transfer of gas from the transmission pipelines to the distribution networks takes place at a number of custody transfer metering stations, often referred to as ‘City Gate Stations’. Here the gas is metered, the pressure reduced and where required odorant is added to make the gas ready for transportation through the distribution network to houses and industry.
The principal role of the Technical Regulator with respect to the gas supply is to monitor the quantity and quality of the gas being supplied into the distribution network and onto the consumers. Should there be a gas supply emergency; the Technical Regulator will act within the provision of the legislation to ensure that the impacts upon the South Australian community is minimised.
AGN is the owner of and is licensed to operate the natural gas distribution networks in South Australia. AGN has contracted APA Group to operate these networks on its behalf. In addition, AGN also owns a number of small gas systems, typically referred to as ‘farmtaps’. The farmtaps supply gas to typically a single industrial/commercial consumer that is fed directly from the transmission pipeline (see Table 2-1).
Over the last 12 months there has been a slight decline (3.9%) in the amount of gas consumed within the networks in South Australia despite the increase in the total number of consumers (1.6%). This is consistent with our observations in the 2013/14 report.
Table 2-1: Annual quantity of gas entering AGN’s SA networks from different sources
Source of Supply To the Gas Quantity (TJ) Networks Including QSN (1 July 2014 – 30 June 2015) Moomba and QSN (MAP Gas) 22,271 including farmtaps SEA Gas 10,264 Limestone Coast Region 0 TOTAL 32,535
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It can be seen from Figure 2-4 that overall amount of gas entering into the distribution network has continued to decline since 2002/03. Overall the trend for utilising gas is downward for both direct use and generation of electricity in South Australia.
Gas Quantity (TJ) 44000 42000 42930 40000 40564 37720 37723 38000 38917 36000 37983 38412 38003 36925 33855 34000 35473 32535 Gas Gas Quantity(TJ) 32000 34129 30000 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15 Year
Figure 2-4: Trend in the quantity of gas entering the distribution system 2.1. Natural Gas Infrastructure In South Australia, natural gas is distributed through AGN’s networks to approximately 430,244 consumers (see Table 2-2). These networks consist of approximately 8,042 km of gas pipes and are operated and maintained by APA Group for AGN. Gas from the distribution system is then supplied to consumers in accordance with their contract with their retailer. The Technical Regulator monitors the operation of the gas distribution networks to ensure that the gas is supplied safely and that the quantity is secure and quality is correct for the use by all consumers.
Table 2-2: Approximate number of consumers in the natural gas distribution networks in South Australia
Network location Consumers (as of 30/06/2015) Adelaide, including Virginia, Waterloo 410,082 Corner and Two wells Whyalla 4,055 Port Pirie 5,339 Mount Gambier 8,682 Peterborough 74 Nuriootpa 926 Angaston 328 Tanunda 23 Berri/Glossop 97 Murray Bridge 419 Freeling/Wasleys 219 Total 430,244
2.2. Safety of Natural Gas Infrastructure
2.2.1. Safety, reliability, maintenance and technical management plan (SRMTMP) A SRMTMP forms an integral part of managing the risks to the South Australian community associated with operating the gas distribution networks and of monitoring compliance with technical standards and codes. The SRMTMP demonstrates the means by which an operator of the gas distribution network will comply
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with the direct requirements of the legislation including the standards and codes called up by the legislation. The SRMTMP requires reporting against a number of key performance indicators (KPIs) and information regarding incidents and complaints (see Appendix 6).
Following the requirement under the Gas Act 1997, the SRMTMP can only be approved by the Essential Services Commission of South Australia (ESCOSA) following the recommendation of the Technical Regulator.
In August 2014, APA Group, on behalf of AGN, submitted a revised SRMTMP to the Technical Regulator seeking a recommendation for approval by ESCOSA. A number of discussions between the Technical Regulator and the stakeholders ensured that the SRMTMP met all the requirements of the legislation and the distribution licence, thereby safeguarding the interests of the community. The Technical Regulator recommended approval of the SRMTMP to ESCOSA.
AGN’s gas distribution licence explicitly requires it to include a detailed Leakage Management Plan (LMP), an Asset Management Plan (AMP) and a Mains Replacement Plan (MRP) in its SRMTMP. Following a review of these plans for 2014/15, the Technical Regulator provided advice to ESCOSA in relation to their acceptance.
The Technical Regulator used the following techniques to monitor compliance with AGN’s SRMTMP during 2014/15:
auditing AGN’s and APA Group’s compliance with specific sections of the plan; reviewing the results of an independent technical auditor engaged by AGN; reviewing the results of the internal auditing processes used by APA Group; reviewing the prescribed set of KPIs reported to the Technical Regulator and ESCOSA by AGN; regular technical meetings and discussions with AGN and APA Group.
The specific processes of monitoring and auditing for safety and technical compliance are described in Section 2.2.3.
The KPIs detailed in the SRMTMP cover a number of areas including safety, gas measurement, gas quality, reliability and gas connections (see Appendix 6 for details).
The Technical Regulator noted that the KPIs indicate that AGN’s distribution systems are generally in a sound condition and are being competently operated. There is some concern about the condition of the remaining cast iron (CI) and unprotected steel (UPS) mains and high density polyethylene (HDPE) mains within the network.
2.2.2. Gas Measurement Management Plan (GMMP) A GMMP is required as a condition of a distribution network licence. Detailed requirements are set out in the Gas Metering Code issued by ESCOSA. It forms an integral part of managing the risks associated with the installation and maintenance of gas meters to an acceptable level.
In August 2014, AGN submitted a revised GMMP for 2014/15. Following a thorough review to ensure compliance with legislative and Code requirements, the Technical Regulator recommended approval of the GMMP to ESCOSA.
Following a review of AGN’s GMMP for 2014/15, the Technical Regulator expressed concern that there has been a significant increase of overdue gas meters since last year. There were 1282 gas meters with a 10 year life outstanding at July 2015 compared with 668 at the same time last year and 213 gas meters with a 15 year life outstanding at July 2015 compared with 163 at the same time last year. The Technical Regulator was advised that the transition to a new contractor to carry out periodic meter changeovers has meant that the number of overdue gas meters is higher than at the end of the previous year.
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Figure 2-5: Example of a gas meter The Technical Regulator noted that the KPIs, provided by AGN in its Annual Report 2014/15 to the Technical Regulator, have indicated that the measurement accuracy for the heating value determination was within the prescribed limits. The heating value is a measure of the energy being used and this must be provided accurately in the bill to gas consumers.
2.2.3. Auditing for Safety and Technical Compliance The Technical Regulator uses three types of audits to obtain assurance that the implementation of AGN’s SRMTMP and GMMP meets the requirements prescribed by the Gas Act 1997, the Gas Regulations 2012, ESCOSA’s Gas Distribution and Metering Codes and AGN’s distribution licence conditions. The three types of audits are:
audits performed by the Technical Regulator; independent technical audits arranged by AGN with the results being provided to the Technical Regulator for review; APA Group’s internal audits with the results provided to the Technical Regulator for review.
During 2014/15, the Technical Regulator carried out a series of desktop and field audits of AGN’s SRMTMP. The audits were carried out in areas that directly affect consumers, the general public, and/or the safety, reliability, maintenance and integrity of the distribution network. The audit scope was discussed and agreed with ESCOSA. This provides a consistent approach, prevents duplication and minimises compliance costs.
These audits included a review of the following:
Evidence of completion of outstanding corrective actions on all recommendations noted during the Technical Regulator’s audit in 2013/14; Operational Failure and Incident Investigation Process – review how APA Group manages the investigation of a major incident and then implement any generated recommendations; Systems and procedures to fulfil APA Group’s obligations with respect to installations, operations, maintenance and emergency preparedness of the regional gas distribution network in Mount Gambier. Review of APA’s mains replacement program in Mount Gambier; Gas Emergency Response Management System – review of the processes that APA Group used to manage their response and recovery activities during the gas outage in Whyalla and Port Pirie following the Epic Energy gas transmission pipeline rupture on the 12 April 2015 (See more details in Section 6); Mapping and Records of Asset Locations – review of the processes that APA Group uses for receipt and updated of ‘as-laid’ information to ensure the accurate and timely update of field records for reticulation maps, plans and field sketches;
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Mains Replacement Program (MRP) – review of AGN’s compliance for 2014/15 (e.g. rates, resources, reporting, etc.) with the approved MRP and preparation for compliance with the MRP for the next 12 months (2015/16). Review of the impact of AGN’s mains replacement on the unaccounted for gas (UAFG) level over the last 12 months.
The Technical Regulator’s audits carried out during 2014/15 found, in general, that the implementation of AGN’s SRMTMP, MRP and GMMP (in the audited areas) are meeting the minimum requirements prescribed by the Gas Act 1997, the Gas Regulations 2012, AGNs distribution licence conditions, safety and technical standards, and industry codes.
APA Group provided documents which assured the Technical Regulator that their staff have sound and well-developed systems in place to ensure that the risks to the South Australian community from the operation of the distribution networks are managed to an acceptable level. It also presented evidence that adequate systems are in place for ensuring the implementation of procedures for the training and assessment of competency of APA Group staff (and contractors) in the audited areas.
The audits found that:
AGN replaced 266 km of gas mains in 2014/15 and a further 289 km is expected to be replaced in 2015/16; The UAFG level was reduced from approximately 1,331 TJ to 1,212 TJ in 2014/15; AGN and APA Group carried out their response and recovery activities to restore gas supply to Whyalla and Port Pirie residents following Epic Energy South Australia (EESA) gas transmission pipeline rupture in a safe and professional manner and in accordance with their Emergency Response Plan.
The Technical Regulator’s audit identified some minor operational / technical areas that may need attention and corrective actions. To assist APA Group with those actions, an audit report that addresses the observations, comments and/or recommendations on each area audited will be prepared.
2.2.4. Gas Incidents Gas incidents that involve death, or injury to a person requiring medical assistance, property damage above $5,000 or a dangerous situation involving a pipeline operating above 1,050 kPa, must be reported to the Technical Regulator. Under the Gas Regulations 2012 and the requirements of AGN’s SRMTMP, the required time frame for reporting will vary with the severity of the incident.
All incident reports are registered in the ‘Technical Regulator Incident Database’ and are regularly reviewed and, where appropriate, the incidents are investigated.
There were no deaths from distribution system incidents during 2014/15. However, there was one incident which involved personal injury.
In February 2015, the Technical Regulator was notified about and investigated an incident when an APA Group contractor was injured while he was purging the inlet service following mains replacement. There was a fire and the contractor sustained burns to the hands and face and was admitted to hospital for assessment and treatment. APA Group investigated the incident and submitted to the Technical Regulator their incident investigation report inclusive of recommended corrective/preventive actions.
These corrective/preventative actions have been reviewed by the Technical Regulator and they are deemed to be satisfactory for minimising the risks of re-occurrence of a similar incident. The Technical Regulator monitored the implementation status of all recommended actions. The incident was also reported to and investigated by SafeWork SA.
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In April 2015, a potentially serious incident occurred when a 4WD vehicle came into contact with an above ground high pressure gas regulator located on the side of South Road in the proximity of the Tonsley Hotel at Clovelly Park and caused a gas leak. The vehicle ended up positioned on top of the regulator (See Figure 2-6). A section of South Road was closed to traffic near the incident site in both directions and local residents were advised by emergency services to remain indoors. Police, Metropolitan Fire Service (MFS), Ambulance and media were in attendance. APA Group crews took approximately 3 hours to control the gas leak and make the site safe.
Figure 2-6: Gas incident – car bumped into an above ground high pressure gas regulator The Technical Regulator attended the incident site and carried out its own investigation. Based on the findings and observations, the Technical Regulator expressed its own concerns to AGN and APA Group about the location and protection of the above ground gas regulators in the public places. The Technical Regulator’s concerns in relation to the location, accessibility, protection and maintenance of the isolation valves were also raised with APA Group. The Technical Regulator is monitoring how APA Group addresses the concerns to ensure the safety of the SA public by reducing/eliminating any potential risks from the above gas regulators.
The Technical Regulator also receives reports on other incidents such as outages affecting more than five consumers. The size and nature of an outage can vary greatly but major outages are infrequent in South Australia. In 2014/15 there were 15 such incidents.
There were two major incidents that affected a large number of consumers and they occurred in:
Whyalla and Port Pirie, where 9,575 consumers (4,001 in Whyalla and 5,574 in Port Pirie) were affected for approximately 8 days (See more details in Section 6); West Beach, where 299 consumers were affected for approximately 20 hours.
In August 2014, an APA Group contractor was working to complete mains replacement activities in West Beach. Prior to the disconnection of temporary feeds to the area, a valve which was installed on the main trunk feed was to be turned on to supply the sections of network which had been supplied by the temporary feeds. On the day of the incident, the temporary feeds were disconnected but the valve was not turned on resulting in loss of supply to 299 consumers. APA Group kept the Technical Regulator informed of its turn off and relights activities. The Technical Regulator also reviewed APA Group’s incident investigation report in which they had recommended a number of improvements to the relevant work procedures to avoid any future reoccurrence. The Technical Regulator has been monitoring the implementation status of the recommendations.
Throughout all major consumer outages and incidents, the Technical Regulator monitors the outage and assesses the adequacy of the response. This has provided a level of confidence that the operational and maintenance strategy employed by APA Group, on behalf of AGN is effective.
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In 2014/15, both APA Group and the Technical Regulator continued, as in previous years, to conduct a number of discussions with the Metropolitan Fire Services (MFS) and representatives of other emergency services about appropriate actions that should be taken when responding to gas incidents.
The Technical Regulator supported a program entitled ‘Gas Awareness For Emergency Services’ that APA Group carried out for the MFS in 2014/15 (5 presentation sessions). This is a program to ensure that the MFS is aware of the properties and characteristics of gases, how gas networks operate and how the MFS can work in successfully with APA Group crews to safely control a gas emergency.
APA Group and the Technical Regulator also requested that emergency services endeavour to consult APA Group before turning off valves and/or squeezing off a gas main to make a site safe.
2.2.5. Third Party Damage Damage to the distribution systems (mains and services) caused by third party activities constitutes one of the greatest gas related risks to the South Australian community because it can result in large volume gas escapes. There were 672 of these incidents reported during 2014/15 (See Figure 2-7). AGN reports the number of these incidents annually to the Technical Regulator as one of its KPIs (see Appendix 6 for further KPI data).
Third Party Damage
1000
928 948 800 888 924 778 796 600 714 741 667 672 545 511 400
351 200
Numberofthird parties damage 0 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15
Year Figure 2-7: Trend in Third Party Damage to Mains and Services A major factor contributing to the damage of mains and services is a lack of notification from a third party to the gas distributor prior to any expected activity in the vicinity of the mains and services. In South Australia, APA Group utilises the “Dial Before You Dig” service in order to minimise the likelihood of damage.
This service allows APA Group to advise about the location of gas pipes and to assess the associated risks of the activities proposed by third parties. During 2014/15, APA Group provided approximately 41,189 location services to various third parties. The number of location services provided was higher than in 2013/14 (33,609).
The Technical Regulator monitors the effectiveness of this service via frequent discussions with APA Group, annual audits and the review of APA Group’s annual operational reports. These discussions found that the Dial Before You Dig (DBYD) system provided an adequate, detailed and prompt asset information and field checking service.
In 2014/15, APA Group continued to promote its ‘Gas Main Awareness Program’ to reduce the number of gas incidents caused by third parties. It conducted three training sessions and carried out other means of communications (e.g. meetings, letters, emails etc.) to familiarise metropolitan and regional councils, major civil works contractors, other utilities (e.g. SA Water, SA Power Networks and Telstra) and emergency
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services with the existence and identification of AGN’s distribution infrastructure. The Technical Regulator strongly supports and monitors these APA Group activities.
In 2014/15 the Technical Regulator addressed and resolved with APA Group’s assistance numerous technical enquiries and concerns which were directly made to the Technical Regulator by third parties involved in various works in the vicinity of AGN’s distribution infrastructure (see an example below).
Following gas incidents involving the road profilers at the Mitcham Council areas and a subsequent enquiry from Mitcham Council, the Technical Regulator facilitated and monitored the outcomes from the discussions between Mitcham Council and APA Group. The purpose of the discussions was to ensure that the risks of re-occurrence of potentially serious incidents associated with the shallow location of a gas pipe, while the Council contractors carry out resealing roads around the foothills, would be minimised in future. The Technical Regulator was assured by both parties that they were pleased from the outcomes of the discussions.
In 2014/15, the Technical Regulator commenced a discussion with AGN and APA Group about the potential development of ‘Fact Sheets’ on their websites (similar to the ‘Service and Installation Rules’ published by SA Power Networks). The ‘Fact Sheets’ could provide the appropriate stakeholders and the general public with more transparency over their operation of gas distribution networks in South Australia. The ‘Fact Sheets’ information could provide assistance in reducing the risks of any potential gas incidents which may be caused by third party activities in the proximity of AGN’s gas distribution networks. The Technical Regulator was assured by AGN and APA Group that the appropriate ‘Fact Sheets’ will be developed and published on their websites in the near future.
2.2.6. Gas Leak Public Reports The identification, location and repair of leaks are the key to the safe operation of the distribution network. The public’s safety is a principal priority for the Technical Regulator, distribution system owners and operators. Should a pipeline fail, it could result in a leak that migrates through the ground to a confined space (e.g. a cellar) and thus would pose a major risk of fire or explosion. Any gas escapes that are found in the distribution system would have been detected through either public reporting (reactive) or regular leakage surveys (proactive).
The Technical Regulator noted that in 2014/15, there were 4,401 gas mains and service leaks reported by the public including the 672 instances of third party damage and 1,687 public reports where APA Group attended but no leak was found. Figure 2-8 shows that the number of gas mains and service leaks reported by the public significantly decreased over the last year.
The Technical Regulator was advised that the following factors contributed to the decrease of public reported leaks in 2014/15:
APA Group decreased the odorant level from 11mg/m3 to 10mg/m3 in the gas distribution network on 3 November 2014; AGN’s ongoing mains replacement program.
The ongoing mains renewal and mains and services repair strategy of AGN is expected to improve the condition and reliability of the gas distribution network. Over time it is expected that this should further reduce the number of gas escapes reported. The Technical Regulator continues to monitor the gas leak data, especially in relation to the mains replacement strategy.
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Gas Leak Public Report 5000
4000 4684 4401 3945 4101 3980 3834 3618 3826 3652 3565 3000 3392 2000 2200 2359
1000 Numberofpublic report 0 02-03 03-04 04-05 05-06 06-07 07-08 08-09 09-10 10-11 11-12 12-13 13-14 14-15 Year
Figure 2-8: Trend in public reports of gas mains and service leaks
2.2.7. Leakage surveys Leakage surveys are the key proactive maintenance strategy employed by the distribution system operator to manage leakage and determine the condition and reliability of the gas distribution network. The approach to leakage surveys is currently risk-based; ‘high consequence’ locations are surveyed more frequently. APA Group reports the results of the leakage surveys to the Technical Regulator annually as one of its KPIs (reported KPIs for 2014/15 are included in Appendix 6, Leakage Survey information is in KPI 4.4).
Figure 2-9: APA Group recently changed its emergency reporting number to 1800 GAS LEAK.
2.2.8. Unaccounted for Gas (UAFG) and Mains Replacement Plan (MRP) UAFG is the difference between the measured quantity of gas entering and leaving the distribution network and is thought to be largely due to leakage. UAFG is an indicator of the general condition, reliability, safety and performance of the distribution network and it is considered to be a lag indicator. The majority of UAFG is associated with leaking of cast iron (CI) and unprotected steel (UPS) mains.
In 2014/15, the Technical Regulator and ESCOSA monitored AGN’s compliance with the UAFG and MRP requirements as prescribed in AGN’s gas distribution licence and the Gas Distribution Code.
The Technical Regulator noted that AGN reported that the UAFG value was 1,212 TJ, based on the Australian Energy Market Operator (AEMO) calculations (as of 30 June 2015). This figure is lower than last
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year’s UAFG value of 1,331 TJ (see Figure 2-10). It should be noted that on an annual basis this value represents approximately 3.7 % of the total quantity of gas that entered the distribution system (32,535 TJ). The decrease of UAFG seems to be attributed to the amount of mains replacement this year. This decreasing trend in UAFG over the last five years, after several years of an increasing trend, is a pleasing outcome.
In 2014/15 the Technical Regulator carried out a number of discussions with and provided a submission to ESCOSA on the jurisdictional service standards to apply to AGN for the 2016-2021 regulatory period, predominantly in relation to setting a UAFG target. ESCOSA’s final decision was to not set a UAFG target for 2016-21. Accordingly, rather than ESCOSA setting a UAFG target, it will amend AGN’s gas distribution licence to clarify that AGN is required to comply with any UAFG management requirements set by the Technical Regulator. This will allow the Technical Regulator to develop an appropriate UAFG management strategy in consultation with AGN.
Unaccounted for Gas (TJ) 2500
2000 2153
2133 1940 1917 1500 1805 1680 1744 1493 1485 1482 1000 1331
UAFG UAFG (TJ) 1212 1022 500
0 02-03 03-04 04-05 05-06 06-07 07-08 08-09 09-10 10-11 11-12 12-13 13-14 14-15 Year
Figure 2-10: Trend in Total Amount of Unaccounted for Gas (UAFG) Following a review of the MRP for 2014/15, the Technical Regulator noted that AGN totally replaced 266 km of gas mains, well in excess of the regulatory target of 233 km for 2014/15 (predominantly CI and UPS mains). This is a combination of carry over block replacement from 2013/14 and the new block replacement which was scheduled for 2014/15. The Technical Regulator noted that the annual replaced length of gas mains was one of the largest that AGN has completed over the last 13 years.
The Technical Regulator expressed concern that AGN has failed in 2014/15 to carry over any of outstanding block mains replacement in the Adelaide Central Business District (CBD) from 2012/13 and 2013/14 (approximately 30 km). In 2014/15 AGN has replaced 17.6 km in the CBD which represents its regulatory target for this financial year (18 km). The Technical Regulator was advised that AGN is managing risks associated with gas mains being not replaced in the CBD in accordance with its regulatory commitment by carrying out regular leakage surveys and monitoring public gas leak reports. The results from these activities indicated that there has not been any deterioration in gas mains integrity within the CBD over the last three years.
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Figure 2-11: Mains replacement and welding of a joint AGN also advised the Technical Regulator that it has budgeted to replace a further 289 km of gas mains in 2015/16 (this includes 20 km of gas mains to be replaced in the CBD).The Technical Regulator noted that, in addition to CI and UPS mains replacement (220 km), AGN will commence work in 2015/16 on the replacement of 69 km of HDPE mains prioritised as locations of greatest risk.
In 2014/15 the Technical Regulator participated in and provided the appropriate technical comments at the Stakeholders Engagement Consultation meetings organised by AGN. AGN organised the meetings as part of the requirements from the Australian Energy Regulator (AER) prior to AGN’s submission of its Access Arrangement 2016/2021 documentation to AER. AGN’s proposed mains replacement for 2016/21 was amongst other safety and technical issues associated with a safe operation of the gas distribution networks in South Australia that was discussed at the meetings.
2.3. Safety of Liquefied Petroleum Gas (LP gas) Distribution Networks In addition to natural gas distribution networks, there are eight separate LP gas distribution networks in operation in South Australia (Table 2-3).
In 2014/15, the Technical Regulator monitored technical compliance to ensure that the construction, commissioning and operations of the LP gas distribution networks is undertaken according to the appropriate standards and gas industry practices.
Figure 2-12: LP gas storage tanks at Roxby Down
The Technical Regulator was advised by Environmental Land Services (Aust.) Pty Ltd (ELS) about the further expansion of its LP gas distribution network at the Bluestone Estate development in Mount Barker. As of 30 June 2015, there were 495 consumers connected at the site (including the Lifestyle Village and
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Scarlet Crest Estate). It is expected that around 680 residents will be connected to the LP gas distribution network once the Bluestone Estate development will be completed in 2015/16. The Technical Regulator carried out numerous technical discussions with ELS during the relocation process of the existing LP gas storage facility to a new location. The new LP gas storage facility with more LP gas tanks at the site will assure that the security of LP gas supply to the residents at the Bluestone Estate will not be affected as demand increases.
In 2014/15 the Technical Regulator monitored progress in the construction of ELS’ new LP gas distribution networks in Mt Barker at the Aston Hill Estate (470 allotments approved with the potential to increase by another 1,900 allotments) and at the Springlake Estate (500 allotments).
The Technical Regulator was advised by Origin Energy LPG Ltd (Origin) that there were only two new connections from mains to houses at the Cape Jaffa Anchorage residential estate in 2014/15. Origin also advised the Technical Regulator that there will be no further mains extensions required until development at the site increases over time. This development had aimed for around 569 consumers and the construction was originally planned over seven stages.
Table 2-3: LP gas distribution networks in South Australia
Length of Operating Number of Network Location Owner/ Operator Main (m) Pressure (kPa) consumers
Roxby Downs Origin Energy LPG 31,381 120 1,521 Victor Harbor (Rosetta Origin Energy LPG 5,474 105 411 Retirement Village) Renmark (Jane Eliza Estate) Origin Energy LPG 2,736 140 96 Port Lincoln Origin Energy LPG 4,075 105 150 Wallaroo Origin Energy LPG 6,355 105 153 Cape Jaffa Anchorage Origin Energy LPG 3,600 70 19 Clare (Hanlins Rise Estate) Elgas Ltd 1,900 140 65 Mount Barker (Bluestone Environmental Land Estate, Lifestyle Village and Services Pty Ltd 11,025 100 495 Scarlet Crest Estate) (ELS)
2.3.1. Auditing for Safety and Technical Compliance The distributors and retailers of reticulated LP gas in South Australia are required to have the licence or licences relevant to their operations granted by ESCOSA. These licences are subject to a number of conditions to ensure that the safety and technical requirements of the Gas Act 1997 and Gas Regulations 2012 apply. Network owners operate their LP gas distribution networks under a SRMTMP approved by ESCOSA on the recommendation of the Technical Regulator.
In August 2014, all distributors of reticulated LP gas submitted their SRMTMPs to the Technical Regulator seeking a recommendation for approval by ESCOSA. Following a number of discussions between the Technical Regulator and stakeholders, the Technical Regulator recommended to ESCOSA that SRMTMPs be approved as they met all the requirements of the legislation and the distribution licence, thereby safeguarding the interests of the community.
The Technical Regulator monitors compliance with the approved SRMTMPs by:
auditing compliance with the plans; analysing incident reports; regular meetings and discussions with the LP gas distribution networks operators.
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In 2014/15, the Technical Regulator carried out field audits of the approved SRMTMPs and held regular meetings and discussions as the means of obtaining assurance that Origin at Cape Jaffa Anchorage, ELS at Mt Barker and Elgas Ltd at Clare effectively comply with their SRMTMPs in the operation of their LP gas distribution networks in South Australia.
The Technical Regulator was satisfied that the risks to the community from the operation of the LP gas distribution networks are being managed to an acceptable level by competent and appropriately trained personnel.
2.3.2. Incident Reporting As is the case with natural gas distribution, LP gas incident reports are registered in the ‘Technical Regulator Incident Database’ and reviewed by the Technical Regulator. Where found to be necessary, the reported incidents will be investigated.
During 2014/15, there was one reportable incident involving the LP gas distribution network in Wallaroo. On 23 May 2015, the Technical Regulator was notified that all LP gas consumers at the Wallaroo Marina (approx. 160) lost their gas supply from the Origin Energy LP gas distribution network as the tanks at the site ran ‘out of gas’ and were empty. The Technical Regulator monitored the implementation of the recovery plan carried out by Origin and APA Group (the Origin’s contractor responsible for operation and maintenance contractor of the LP gas network in Wallaroo). The recovery plan covered the following major activities:
transport arrangement to fill two tanks with LP gas at the site; turn offs of all meters before LP gas was introduced to the network; relights of all consumers once LP gas was already injected into the network.
LP gas supply was safely restored to all consumers within approximately 24 hours by APA Group. Origin carried out an immediate investigation into the outage. The investigation established that the outage was caused by a scheduler who did not have the appropriate training in a new scheduling system (called ‘Route Planner’) which was recently introduced by Origin. The Technical Regulator received and reviewed the Origin incident investigation report which outlined an action plan with the appropriate recommendations to prevent repeating of a similar outage.
During 2014/15, there were a number of cases where the Technical Regulator undertook an investigation of issues in relation to the installation and supply of LP gas. An example of this is provided below.
The Technical Regulator has had a number of meetings and discussions with Retire Australia, owner and operator of the LP gas reticulation installation at the Laurels Retirement Estate (140 units) in Mt Barker. The quality and determination of unaccounted for gas (UAFG) reported to the Technical Regulator together with monitoring systems and actions to mitigate risks of leakage at the site were of some concern and discussed. Retire Australia assured the Technical Regulator that they believe that all traceable leaks of gas have been located and repaired but there remain an unknown number of very minor points of escape that are, they believe, underground and virtually impossible to find. Retire Australia therefore believes that the level of safety risk to their residents is acceptably low, their gas system is monitored adequately and is under ‘as well as can be expected’ control. The Technical Regulator continues to monitor Retire Australia’s actions to mitigate risks of leakage at the site.
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Section 3: Natural Gas and LP gas Installations The gas installation commences downstream of the infrastructure (billing gas meter or LP gas first stage regulator) connected to LP gas cylinders owned by the gas entities. The condition and safe use of the installation is the responsibility of the owner/operator of the installation. The gas installation generally includes appliances, pipe work, flueing, ventilation and controls.
3.1. Responsibilities The Technical Regulator is responsible, under the Gas Act 1997 (the Act), for the monitoring and regulation of safety and technical standards with respect to gas installations in South Australia. This involves ensuring that installation work is performed in a safe manner, using appropriate methods and materials that are compliant with relevant Standards. The monitoring and regulating of gas installation work is carried out by officers authorised under the Act.
The Gas Regulations 2012 call up the Australian Standard AS/NZ 5601 – Gas Installations including any standard called up by or under AS/NZ5601. The regulations require that a certificate of compliance must be issued by the gas fitting contractor to the client within 30 days of the completion of all installation work. The Energy Products (Safety and Efficiency) Act 2000 requires that certain proclaimed gas appliances must be labelled as evidence that they are approved to appropriate standards by a certification body or the Technical Regulator.
3.2. Residential and Light Commercial Gas Installations Generally, gas installation work involves the connection of new gas appliances. Industry sources indicated that approximately 67,000 new domestic and light commercial gas appliances were sold and installed in South Australia during the 2014/15 year. This included multiple appliances installed in new premises as well as single additional and replacement appliances in existing premises.
In addition to the installation of new gas appliances a significant amount of work involves the repair, replacement and extension of existing gas installation pipe work and components such as flues and ventilation equipment. Some 9,500 installations fell into this category. Repair, replacement and extension work when combined with new appliance installations, totals an estimated 76,500 gas installation jobs carried out during the year.
Statistics indicate 8,544 new residential, including industrial/commercial natural gas connections were made to the AGN distribution system during the year. In addition an estimated 2,400 new LP gas connections (by various LP gas suppliers) were made to residential and light commercial premises over the same period.
In larger new residential developments where natural gas is not available, it is becoming increasingly popular to supply LP gas by means of reticulated LP gas systems supplied from large storage tanks located on the perimeter of the estate. This has some safety advantages as it removes the need for individual LP gas cylinders at each home to be replaced when empty or having individual tanks refilled by tankers. The estimated 10,944 new natural gas and LP gas connections facilitated the supply of gas to 23,335 individual new gas appliances*.
* Based on an industry accepted average of 2.5 gas appliances installed per new residential or new commercial connection
3.3. Industrial and Large Commercial Gas Installations The Technical Regulator provides advice on the interpretation of gas standards and an advice service to hydraulic consultants, architects and builders as well as to gas contractors. This represents a significant proportion of the work done by the gas installation and appliance section. Most advice of this type involves commercial or industrial premises and site visits are required to verify that the advice given is consistent with the actual site conditions. This service, whilst resource intensive, is very important and effective. It is
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far better to identify and resolve installation issues in advance than to later discover non-compliances and potentially unsafe situations in areas where they may create a hazard or delay building handover.
The Technical Regulator was involved in providing oversight on several significant Industrial and Commercial (I&C) gas installations during 2014/15. The Technical Regulator’s involvement often extends over months or even years on some larger jobs and often requires multiple site visits.
Examples include:
The performance based design at the New Royal Adelaide Hospital (NRAH);
Figure 3-1: New Royal Adelaide Hospital
The NRAH is the largest commercial construction currently under way in South Australia and has been awarded major development status. The gas installation at the NRAH is significant and complex with natural gas reticulated throughout the site at multiple pressures. The performance based design for this installation does not conform to the prescriptive, deemed to comply provisions of the gas installation standard. The complex gas installation at the NRAH was designed by a consortium of engineers and suppliers in consultation with the Technical Regulator for regulatory advice and comments relating to the pipe material selection within the building, pipe support systems, gas isolation, purge and sample points on the 300 mm diameter stainless steel ring main. Performance based gas installation designs must be engineered using sound principals, then risk assessed in the context of the installation environment and peer reviewed by independent engineers prior to consideration by the Technical Regulator. The Technical Regulator then reviews the assurances, designs and risk assessments prior to providing regulatory comment as to their implementation. The NRAH project continues to involve resources to review submissions covering stages of the installation and the Technical Regulator attends numerous site meetings to inspect the various stages of gas installation work as part of the construction process. This collaborative investment ensures that the installation meets the performance / prescriptive objectives of the standard thus eliminating delays or expensive rework to conform to the requirements on this important public asset. Throughout 2014/15 the Technical Regulator has reviewed a number of modifications with: the gas pressure regulator station and enclosure ventilation designs; full procedures for the pressure testing and purging operations of the ring main and risers; safety plans, same work method statements and risk assessments associated with this work prior to various contractors undertaking the staged work.
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Gas is now on the site and purged through the ring main and applicable riser stack gas lines. Further submissions are yet to be made to the Technical Regulator in relation to the safety testing and certification of gas fired type B stationary gas engines and hot water boilers during the final stages of building fit out. The contractors responsible for the gas installation consult regularly with the Technical Regulator to ensure that the new gas installation stages meet the relevant requirements and that the individual contractors responsible for commissioning type B gas equipment on site have made the necessary application to have them individually tested and certified by certifiers recognised by the Technical Regulator prior to releasing gas for commissioning. The gas installation is progressing well and within the scheduled timeframes.
The performance based design of the CAVPOWER engine test bed facility at Wingfield;
Figure 3-2: CAVPOWER engine test Expansion / upgrade at DeVine Ripe including 10 Capstone Micro turbines for power generation;
Figure 3-3: Micro turbines for power generation
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The SANTOS well head training facility at the TONSLEY TAFE with elevated pressure natural gas used for fuelling the gas jack compressor node and a 24 litre GE Waukesha gas engine to circulate compressed fluids to simulate exploration well head conditions for training production well head operators.
Figure 3-4: SANTOS training facility at Tonsley compound 3.4. Auditing for Compliance
3.4.1. Proactive Audits The current strategy, where possible, is to proactively audit samples of the gas installation work of each contractor in South Australia annually. Gas contractors performing LP gas work in the more remote regional areas may be audited less often because of logistical and resource constraints. An estimated 68,500 residential and light commercial gas installation jobs were completed in South Australia during 2014/15 and of these installation jobs 1,091 were audited in this manner.
Table 3-1: Results of installation auditing
Area of Audit 08/09 09/10 10/11 11/12 12/13 13/14 14/15
Domestic/light 1397 1210 1276 1195 1034 960 1091 commercial audits
100% Domestic safety checks at all new meter 8850 8800 10351 8919 8621 8198 8544 connections *
I&C audits 112 96 96 99 91 75 87
Caravan & Tourist Park 18 32 10 29 28 22 27 gas safety audits.
Complaints resolved 780 810 670 456 550 680 709
Investigative interviews 20 18 20 16 15 12 11
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Area of Audit 08/09 09/10 10/11 11/12 12/13 13/14 14/15
Warning letters sent 144 73 90 66 68 63 65
Expiation Notices issued 8 6 7 8 6 6 0
Referrals to CBS – 17 11 13 13 10 8 3 re: licensing issues 16 10 20 20 Referrals for remedial 14 6 4 training.(Self-initiated (3) (2) (8) (8) enrolment)
* New residential consumer installation and appliance safety checks were performed by AMRS (Aust) P/L and Phoenix Pty Ltd technicians (contractors for APA Group) prior to connection to the natural gas distribution system for the first time under an agreement with the Technical Regulator.
An estimated 920 large commercial and industrial gas installation jobs were completed during the period; and Technical Regulator pro-actively audited 87 of these jobs for compliance with AS 3814 – Gas Fired Industrial and Commercial Appliances and AS/NZS 5601 – 2013 Gas Installations.
Figure 3-5: Gas installation audit by an Authorised Officer
The Technical Regulator uses a standard audit pro-forma to record audit results. Where work is satisfactory a copy of this form is provided to the installation owner and the contractor. Where there are non- compliances an escalation process is used (See section 3.4.7 for more detail).
Where new type B (large industrial and commercial) gas appliances are installed it is mandatory that they are inspected for compliance with the Australian Standard AS 3814 before they are operated commercially. The OTR is not resourced to do this work and, as a consequence, the Technical Regulator undertook a national search for organisations with experience and competence in Type B gas appliance inspection and approval.
Select Solutions P/L - a division of the gas distributor SP Ausnet and Tamar Gas Certification (TGC) were both assessed as technically competent and approved by the Technical Regulator to undertake this task. The Technical Regulator in turn carries out sample audits of Type B certification work performed by both certifiers. The new arrangement has been operating successfully since their commencement in 2014.
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Figure 3-6: Example of Gas Audit Form
3.4.2. Mobile installations in Recreational Vehicles The Technical Regulator pays close attention to the standard of LP gas installations and appliances in caravans, motor homes, houseboats, river craft and small sea going vessels - including prawn boats (where high pressure gas burners are used to cook prawns at sea).
Imported recreational vehicles (motor homes, caravans and camper trailers) as well as imported yachts warrant particular attention because they may include unique proprietary gas systems and appliances that are not certified to an Australian Standard. The Recreational Vehicle Manufacturers Association of Australia (RVMAA) is represented on the Gas Installations Standards Committee (AS/NZS 5601).
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Figure 3-7: Example of an imported mobile home with modifications, i.e. new LP gas cylinders, 2 stage regulator, pipe work and appliances to enable certification to AS/NZS 5601.2.
The RVMAA has also expressed concern about unfair competition from privately imported caravans and motor homes where cheaper imports, usually from the UK, Europe or USA do not comply with gas, electrical and, in some cases, roadworthiness requirements, The Technical Regulator has discussed this with the road transport safety division of Transport SA.
An agreement has been reached whereby owners of imported recreational vehicles, undergoing roadworthiness checks prior to registration, are directed to have gas installations and appliances checked for compliance with Australian Standards by a licensed gas fitter.
Similar concerns apply to some imported boats (yachts & cruisers). Gas safety is an ongoing consideration when gas system or appliance repairs and maintenance is required due to the lack of spare parts. The Technical Regulator encourages the importers to make space provision for appliances during construction of the boat or recreational vehicles and then source appliances certified for use in Australia and fit them on arrival in Australia hence ensuring the provision for spare parts and manufacturer warranty to overcome these issues.
South Australian registered commercial marine and river craft are required to be surveyed biennially by private surveyors accredited by the Department of Planning, Transport and Infrastructure (DPTI). DPTI accredited Marine Surveyors require the owner of a vessel to have a gas safety inspection carried out by a licensed person in advance of the survey and provide the surveyor with copies of the inspection reports (Certificate of Compliance).
As a result of the Technical Regulator’s activity in this area, insurance companies have become more aware of gas safety requirements and now insist that the gas installation is certified before marine or catering vehicle insurance policies will be issued or renewed.
3.4.3. Temporary kitchens at outside events Temporary kitchens are set up to cater for outside public events. Generally these kitchens operate on LP gas supplied from portable cylinders located close by. These temporary kitchens may be located in trucks, trailers, caravans, marquees or even inside permanent structures such as community halls.
The Technical Regulator held 10 pre-event gas safety meetings including power point presentations during 2014/15 with organisers of major events. This was done to ensure that the catering companies and smaller itinerant operators on site are aware of all the gas safety requirements. The main issues that arise relate to installations assembled by the stall holder (using gas hose assemblies) rather than by a gasfitter. Most appliances used at these events are portable burners or barbecue style appliances and it is not mandatory for a gasfitter to connect them.
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The areas that are most closely monitored are the condition and protection of the appliances, gas cylinders, regulators and hoses and ensuring that there is sufficient provision for ventilation and clearance from combustibles especially where traders and public are present. In the example below (figure 3-8) of a temporary cooking setup at an outside event, operators were advised to secure / protect flexible hoses connecting the portable appliances.
Figure 3-8: Example of a temporary cooking setup at an outside event. Where resources allow, the Technical Regulator’s inspectors also patrol public event sites during the set up and the event to ensure continuing compliance. The Technical Regulator works closely with inspectors from SafeWork SA and private event safety consultants in an effort to educate and improve the safe use of gas. As a result of this proactive activity, gas related incidents have declined and safety standards improved significantly. In the example below (figure 3-9) of a coffee percolator machine with a gas boiler installed in a mobile catering trike, operators were advised to have modifications performed by a licensed gasfitter and to have the equipment safety assessed and certified by a recognised safety assessor.
Figure 3-9: Example of a coffee percolator machine with a gas boiler installed in a mobile catering trike.
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3.4.4. Audits of Permanent Gas Installations at Tourist and Caravan Parks The Technical Regulator also focuses on the safety of gas installations in Caravan and Tourist Parks. Some of these Parks are located close to major centres and use natural gas but most use LP gas for hot water and cooking as well as for onsite canteens and laundry facilities.
In addition to communal facilities, the Technical Regulator inspects gas installations on permanently occupied caravans or cabins. Permanent residents pay rent to the park owner for the site but are responsible for their own utility bills as well as any repairs and maintenance to gas installations or appliances. Long term residents are sometimes in poor financial circumstances and gas installation and appliance maintenance may be neglected as a result.
The Technical Regulator may in extenuating circumstances extend the period allowed for the work to be made compliant provided there is no immediate danger to the resident or neighbours. In unavoidable circumstances, where remedial work cannot be delayed, the Technical Regulator’s gas inspectors will either disconnect the gas supply or make an arrangement with the park owner / manager to have the work completed. Twenty seven caravan park audits were carried out during 2014/15, as seen in Table 3-2.
Figure 3-10: Example of a communal cooking facility at a caravan park that required the relocation of the LP gas cylinders away from ignition sources and rectification of the hose connection. Where a caravan is used as permanent accommodation, it is unregistered and the wheels are usually removed and other structures may also be attached from the ground to the van. In this case the installation is treated as a residential dwelling and not a mobile home. The electricity, water and gas are permanently connected.
Table 3-2: Number of caravan park audits in various regions
Location of Caravan & Tourist Parks Number of Parks Total sites* audited during 2013/14
Mid North 13 65
Far North 14 53
* Sites in this context means the rented land occupied by a permanent resident (caravan/cabin)
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The most common non-compliances found were:
Exchange LP gas cylinders located too close to ignition sources; Gas escapes / obsolete pressure regulators that provided no overpressure protection; Insufficient ventilation for appliances in ablution blocks; DIY gas fitting work, non-compliant materials / pipe work or installation techniques.
All non-compliances found were rectified at the expense of residents or caravan park owners.
3.4.5. Effect Burners used in Public Events or Productions The Technical Regulator inspects flame effect burner systems and their associated controls manufactured / assembled by pyro technicians / gasfitters for use in public events such as the Fringe Festival or playwrights at the Festival Theatre.
Manufacturers and event organisers are made aware of their legal and technical responsibilities in relation to the 1997, Plumbers, Gas Fitters & Electricians Act 1995 and Work Health &Safety obligations. Event organisers, operators and constructors must define the tasks, conditions and limitations of the performance or effect in their designs, Safe Work Method Statements and Standard Operating Procedures which must then be risk assessed and controlled to eliminate / minimise risks of injury or damage to property. Participants must also be provided with appropriate training and Personal Protective Equipment and all relevant regulatory jurisdictions notified of the activity.
Figure 3-11: Example of an LP gas effect fire used in a community event - Courtesy of Mr Kevin Godfrey
3.4.6. Installation Audit Results Overall, the standard of fixed gas installations has shown a continued improvement. This trend has not been without the application of significant resources, especially as large distances must be covered to inspect gas installations in regional and remote areas of South Australia. See Table 3-1 for more details.
The ratio of natural gas to LP gas consumers in South Australia is approximately 10 to 1. The number of proactive audits of residential and light commercial installations that were completed in the year was 1,091. The split of natural gas versus LP gas installation inspections this year was 760 and 331.
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LP gas installations are audited at a higher relative rate than natural gas jobs for several reasons:
LP gas is potentially a more hazardous fuel and is heavier than air with much higher heating value; Because of the sometimes more remote location of these jobs there may be the feeling that compliance with Standards is not so important because there is less chance that the Technical Regulator will audit the work; Often existing gas work on site has been performed by unlicensed persons due to the limited availability of skilled licensed persons in some areas or a DIY mentality in some remote areas.
3.4.7. Enforcement Activities for Non-compliant Gas Installations The Technical Regulator’s enforcement activities with respect to non-compliant gas installation work are on a graduated scale which escalates according to the degree of non-compliance found during a pro-active audit or as a result of an inspection prompted by a gas consumer complaint or safety report by the trade.
1. Minor technical non-compliance A copy of the audit pro-forma is left with the owner and another is posted to the installation contractor with a request to remedy the situation. A follow up phone call is made to the owner to confirm that the non- compliance has been remedied.
2. Significant but non-hazardous non-compliance A copy of the pro-forma accompanied by a warning letter is sent to the contractor. The letter, endorsed by the installation owner, asks the gas fitter return to the site within a given time frame, to remedy the non- compliances. The owner is notified that significant remedial work is required. A signed and dated compliance statement must then be sent back to the Technical Regulator by the contractor or owner to confirm that the remedial work has been completed. A follow up inspection may be done at the discretion of the Technical Regulator.
3. Non-compliance posing an immediate danger to persons or property. As above except to make such an installation safe the Technical Regulator’s inspector may be required to isolate an appliance or part of the system or cut off the gas supply to the premises. After the defect has been remedied a signed and dated compliance statement must then be sent back to the Technical Regulator. A follow up inspection will definitely be carried out. An expiation notice may be issued for defective work.
4. Prosecution The Technical Regulator may prosecute a contractor where the non-compliance is so serious as to constitute gross negligence or where a contractor has a history of significant non-compliances. The process is generally as above except in these circumstances it may be that the original contractor cannot, or will not return to site to remedy the non-compliance or sometimes the owner will not allow the contractor back on the site. In these cases, the owner must engage a third party gasfitter to make the installation compliant. A signed and dated compliance statement must then be sent back to the Technical Regulator and a follow up inspection will be carried out.
5. Disciplinary interviews / desk top audits Where repeated non-compliant gas installation work can be attributed to a specific worker or contractor, an interview is arranged. This has been found to be generally much more cost effective than prosecution. The interview is carried out with two authorised officers in attendance and is recorded after the person is first formally cautioned. The aim of the interview is to establish the following:
To identify and emphasise the seriousness of the breaches; To ascertain whether the breaches occurred as a result of negligence or a lack of knowledge; or If the person was working beyond the scope of their licence and personal competence.
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Where a licensing issue is found, the contractor will be referred to Consumer and Business Services (CBS) with a recommendation from the Technical Regulator that disciplinary action be considered to suspend or cancel the gas fitting worker’s registration or contractor’s licence.
Alternatively, or in addition, a recommendation may be made that the worker or contractor attends remedial upskill training to overcome some knowledge or skill deficiency. A total of 65 warning letters were sent to gas fitting contractors during the year.
Investigations and Expiations Notices 30
25 Investigate interviews 20 Expiation notices issued * 15
incident Number 10 investigation
5
0 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15 Year
Figure 3-12: Investigations and Expiation Notices * The process has now changed and expiations are now administered by SAPOL which explained that no expiation notices were issued for 2014/15. The TRs preference is that non-conformances are addressed by the gas fitter and the installation is made safe instead of taking legal action at risk of not facilitating the remediation of the actual non-conformance.
3.4.8. Referrals to Consumer Business Service (CBS) There were three people found to be performing gas installation work whilst unlicensed, unregistered or performing work outside the scope of their licence or registration and they were referred to the licensing authority CBS for action. CBS investigated the matters and discussed the recommendations made by the Technical Regulator.
Where unlicensed work includes significant non-compliances with the Gas Installation Standards, the Technical Regulator recommends that a joint CBS and Technical Regulator interview be conducted. In addition to any penalty applied by the Technical Regulator, CBS can also apply various sanctions including licence suspension and, in extreme circumstances, licence cancellation.
If a person is found to be performing gas fitting work while unlicensed, CBS may, in extreme circumstances, prosecute or as a minimum seek a written assurance that they will desist from this type of work.
3.5. Gas Incidents – Installations Gas related incidents are events where natural gas or LP gas, or their products of combustion, are directly involved (or suspected of being involved) in causing death, injury or property damage. These events are referred to as ‘accidents’ in the Gas Act 1997. The Gas Regulations 2012 require events such as these to be reported within specific time frames, dependent on their severity.
These events are investigated by the Technical Regulator to determine their cause, often in conjunction with other authorities or organisations such as the Metropolitan or Country Fire Services, South Australian
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Police, SafeWork SA Inspectors, medical examiners and insurance companies. Incidents reported to the Technical Regulator are investigated and recorded on the gas incident database. The Technical Regulator’s staff may be called as witnesses in any subsequent legal action.
Occasionally gas installations and appliances are deliberately misused by unlicensed persons involved in illegal activities, for example in the manufacture of illegal drugs.
Figure 3-13: Fire damage to BBQ caused by incorrect procedure in changing 9 kg LP gas cylinder, (i.e. cylinder was left turned on when disconnecting cylinder whilst burners were in use).
Incident Summary No gas related fatalities occurred during the year. However 15 gas related incidents involving injury and/or significant property damage were investigated. These include:
Recreational vehicle, gas explosion in an off road caravan. Swift 500 series cooker is the subject of a recall due to internal aluminium pipe fractures due to vibrations / shuddering when the caravan travels over rough corrugated roads / tracks. ($90,000); Domestic residence, fire involving an external water heater. Carport, car, air-conditioner and eaves damage ($12,500); Domestic residence, occupants received Carbon Monoxide (CO) poisoning from an incorrectly installed room heater that had not been maintained for more than eight years. Occupants recovered and heater replaced; Commercial property, gas leak in new building school evacuated. Incorrect installation of gas valves resulting in loss of gas from LP gas tank. ($1,500); Commercial catering vehicle, flame flash injury to the hand, forearm and face of the operator lighting an LP gas pie warming oven in a mobile catering van due to gas leaking from a loose appliance connection. Suspected DIY maintenance by owner; Commercial premises, gas leak from three hot water boilers when tripped on the high temperature limit devices due to a field wiring issue providing electrical back feed to the electronic burner management controllers. (Near miss incident); Commercial premises, gas smell from hot water boiler in plant room during operation. Fault traced to faulty air modulation motor. Faulty motor replaced and boiler serviced. (Near miss incident); Commercial premises, fire in deep fryer flue way caused by leaking fat igniting. Metropolitan Fire Service extinguished fire and appliance was replaced by licensed gas fitter. ($3,000);
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Commercial premises (workplace), hot combustion product heat plume contacted and burnt the forearm of an operator using a gas BBQ due to incorrect appliance configuration, i.e. top plate cover panel was blocking the flue discharge opening; Commercial manufacturing premises, flame flash fire on a commercial glycerine plate pikelet cooker due to mechanical failure, (cracking) allowing flammable glycerine to spray on the hot operating burner. Incident resulting in 3 persons hospitalised for burns. The equipment was found to be uncertified and was subsequently defected until modifications and certification is completed; Domestic residence, explosion and flame flash fire in laundry where storage water heart was installed. No fault found with the gas installation or water heater. Likely scenario to be leaking butane propellant from an aerosol can or some unknown accelerant vapours igniting off the water heater gas burner flame. Occupant’s legs sustained burns; Domestic residence, flame flash and fire from high pressure leaking gas resulting in burns to two persons attempting to change over a LP gas cylinder on their gas BBQ whilst operating. Likely cause operator error in failing to isolate the gas supply and BBQ controls. ($1,000); Domestic residence, fire at the leaking regulator POL connection to a 9 kg LPG cylinder supplying a portable BBQ when the operator failed to soapy water test the connection when a new cylinder was connected. Incorrect operating procedure.($250); Commercial premises, gas leak from flexible hose assembly when hyperextended as the cooker was pulled out for cleaning by staff. Gas isolated and facility evacuated. Damaged hose was not correctly installed. Replaced per code and tested by a licensed gasfitter. ($330); Domestic residence, owner received flame flash burns requiring hospital treatment when they used a portable ring burner without flame supervision in an unapproved manner to ignite wood logs within a wood fired pizza oven. Operator error.
Comparison of significant incident statistics 8 Property damage over 7 $5000 associated with 6 gas Injuries attributable to 5 gas 4
Number 3 Deaths directly attributable to gas 2 1 0 09/10 10/11 11/12 12/13 13/14 14/15 Year
Figure 3-14: Comparison of Significant Incident Statistics 3.6. Gas Certificates of Compliance (GCC) Compliance with the requirement to issue Certificates of Compliance for gas fitting work continues to improve. During the year, 1,540 GCC blank books were issued to gas fitting contractors by the Technical Regulator. This totals 77,000 individual certificates (50 certificates per book). The Technical Regulator distributes the GCC books free of charge via some 25 major plumbing merchants and Service SA outlets. A sample of a Certificate of Compliance is shown in Appendix 2.
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3.7. Communication and Education
3.7.1. Industry Liaison and Support The Technical Regulator provides information about Standards to gas fitting contractors, architects and engineers, as well as to commercial and industrial users of gas. During the year staff handled 6,750 technical enquiries relating to gas installations or appliances.
The Technical Regulator has developed a series of pamphlets and bulletins which address the most common and straightforward technical enquiries. These are provided at no charge and, in some cases, have both layperson and expert versions depending on the target group.
3.7.2. Technical Presentations The Technical Regulator provided 31 gas presentations during the year. These consisted of 20 technical presentations for gas fitters and other technically qualified groups. In addition, 11 presentations on how to use natural or LP gas safely were provided to community groups and others e.g. caterers or home carers. Key presentations were prepared this year for the following groups (full list of presentations in Appendix 3):
Gas and mechanical services fitters; Ray White Real Estate; Caravan and Camping Association of SA; Registered Training Providers, Tonsley TAFE and PeerTech; Master Builders and Housing Industry Association; Hydraulic Consultants Association of SA; Organisers of outside events (gas safety on temporary kitchens).
3.7.3. Assistance with the Development of Technical Training Courses The Technical Regulator continues to liaise closely with the Office of Consumer and Business Services (CBS) and TAFE / PEER VEET and Training Prospects about gasfitter training curriculums and competencies (CBS regulates the licensing of gasfitters under the Plumbers, Gasfitters and Electricians Act 1995).
3.7.4. Standard Committee Representation – Formulation of Standards The Technical Regulator provides regulatory support to Standards Australia and the gas industry by providing committee representation on behalf of the Gas Technical Regulator Committee (GTRC) on the AS5601 Gas Installation Standard committee.
The purpose of the committee is to review and amend the Part 1 gas installation - general installations and Part 2 LP gas installations in caravans and boats for non-propulsive purposes as a result of new innovations, building practices, materials, appliance technology and work practices.
The standards committee is a gathering of industry subject matter experts representing industry stakeholders, i.e. technical regulators, appliance manufacturers, gas suppliers, utilities / network operators, installers, trainers, and industry bodies such as master plumbers association, plumbing industry commission and Australian building construction board.
The Technical Regulator attends committee meetings to technically review the Standards and submissions for amendments or revisions of the standard. In doing so the Technical Regulator communicates information to and from the trade and Standards relevant to industry stakeholders within the charter of committee protocols to ensure that the industry is included in the development of the standard.
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3.7.5. New Gas Installation Standard called up by the Gas Act The Australian / New Zealand Standard AS/NZS 5601 – Gas Installations Parts 1 and 2 was published in late 2013 and was immediately recognised by the Technical Regulator as the required Standard for gas installations in South Australia. During the period March - October 2014, the Technical Regulator presented 27 technical information sessions to gas fitting contractors and consultants to explain the changes in the new AS/NZS Standard. As a result of the effort put in during the previous year to introduce the AS/NZS Standard, it was found that the trade was aware of the new Standard and the changes required as a result.
To keep the gas industry informed, the Technical Regulator publishes biennially a joint electrical/gas/plumbing industry newsletter – Regulation Roundup. Copies are sent to approximately 2,800 registered gas and mechanical services workers and licensed contractors in the State. Copies are also sent to interstate Technical Regulators and other interested parties in a reciprocal arrangement. The newsletter provides a good conduit for providing information to the contracting trade and allows industry- specific topics of a technical nature to be discussed. Colour printing allows clear photographs of faulty installations and appliances to be included and it continues to be very popular with the trades.
Figure 3-15: Example of Regulation Roundup
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Section 4: Natural Gas and LP gas Appliances 4.1. Gas Appliance Certification The Energy Products (Safety and Efficiency) Act 2000 requires certain proclaimed gas appliances to be tested, certified and labelled before they can be sold, installed and used in South Australia. Gas appliances are classified as either Type A (i.e. generally mass produced, domestic and light commercial) or Type B (heavy commercial, industrial and often unique utilisation). There are currently four Conformity Assessment Bodies (CAB) that can certify Type A gas products in Australia. They are – the Australian Gas Association (AGA), Standards Australia International Global (SAIG) the International Association of Plumbing and Mechanical Officials R & T Oceana (IAPMO) and Global Mark. Their typical certification labels are provided in Figure 4-1.
Figure 4-1: Certification Label Examples
The Technical Regulator sits on the Gas Technical Regulators Committee (GTRC) and as such takes a pivotal role in the GTRC’s activities. The GTRC has introduced a national database for gas appliances certified by the approved CABs and is working towards a national Gas Compliance Mark and Scheme Rules.
4.2. Appliance and Component Recalls and Safety Notices An approved CAB (e.g. AGA, SAIG, IAPMO or Global Mark) can suspend or cancel the certification of a gas appliance or component under certain circumstances. Typically this occurs when:
The manufacturer wishes to change to an alternate CAB; The manufacturer has ceased production of the appliance or component and product certification is surrendered voluntarily; The manufacturer has failed to pay ongoing fees to the respective CAB for annual verification inspections or label costs; The manufacturer has failed to provide the product to the respective CAB for annual verification inspections; The appliance manufacturer has been found to have modified the appliance, without notifying the respective CAB, so that it does not exactly replicate the appliance originally certified; An appliance has been modified in a way that affects its safety or reliability. Where this happens the Technical Regulators will issue a product recall or safety notice; An appliance is found to be defective in service to a point where it is likely to create a hazard (this does not include normal wear and tear or the lack of maintenance by the operator). Where this happens the Technical Regulator will issue a product recall or safety notice.
Note - certification may be reinstated if the manufacturer satisfactorily remedies the non-compliance.
An example of the Technical Regulators activity in this area is provided on the next page.
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In March 2015, a stop sale was announced on many portable butane cartridge cookers that are commonly known as “lunchbox cookers”. This came about following a number of issues involving these appliances Australia wide and the Gas Technical Regulators Committee (GTRC) requesting the Conformity Assessment Bodies (CABs) to retest them. During an extensive investigation of these appliances by the CABs, some of these cookers were found to be faulty with their safety mechanism not engaging when the cartridge became over pressurised and others were found not complying with the appropriate Australian Standard. Because of this the CABs generally withdrew the appliance certificates and thus made these uncertified appliances illegal to sell under the legislation applying in the jurisdictions. Following this action, the Technical Regulator implemented a specific page with a product alert (see Figure 4-3 below) on the website to keep the South Australian public informed and able to make phone and email enquiries. A list of all these portable cookers (including brand, model number and certification number) was made available for people to know whether their appliance was concerned or not and to provide them with appropriate safety advice. The decision to remove the certification on all of the “lunchbox cookers” on the market was then made nationally to help avoid confusion of the public. Over April, following advice from the GTRC, the Australian Competition and Consumer Commission (ACCC) assisted in getting a voluntary recall on these products. The Technical Regulator then provided more details on the webpage on what to do with the faulty appliances and with the remaining gas cans (http://www.sa.gov.au/topics/water-energy-and- environment/electrical-gas-and-plumbing-safety-and-technical-regulation/electricity-and-gas-safety-for- consumers/gas-safety/portable-gas-cooker-safety). In addition, the Technical Regulator has been monitoring the market closely, including Ebay, for all sales of these gas cookers and drawn Ebay officers attention to all illegal cookers that the Technical Regulator has noticed. The Technical Regulator has also communicated to Ebay the stop sale/recall of those appliances and Ebay agreed to redirect sellers to the ACCC website for more information on the stop sale.
4.3. Small mobile LP gas appliances The programme for auditing appliance retail stores continued throughout 2014/15 with 13 retail outlets being audited. This provides an opportunity to check if the retailers are selling only approved, certified equipment and that their displays provide all of the necessary safety information required. In addition, it allows the Technical Regulator to check if these retailers have been notified of any product recall or suspensions and if (or whether) they act in accordance with the notice.
The audits are also an opportunity to educate the retailers to only accept certified goods for sale and to pass on the appropriate safety information to their consumers. It should be noted that any issues that were found during an audit were addressed immediately and the offending product(s) were removed from shop displays and if required, the stock was quarantined until the non-conformance had been rectified. This process was in general, well received by store managers.
Figure 4-2 illustrates the “lunchbox” cooker discussed above. With the older design model illustrated, the pan trivet is reversible for packing and transporting. This is very significant as it is imperative to operate the appliance in the correct configuration otherwise the enclosed gas cartridge will overheat and then very likely explode. These appliances were withdrawn from sale in early 2015, pending some major safety modifications recommended by the GTRC and the CABs. Figure 4-2: An example of a “lunchbox” cooker.
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The figure 4-3 below shows the product alert implemented by the Technical Regulator on the website, as mentioned in the previous case study.
Figure 4-3: The Technical Regulator implemented a specific page with a product alert on its website to keep the South Australian public informed regarding the stop sale of portable butane gas cookers.
How to check whether a gas appliance is certified or not?
If buying directly from a retail outlet, the retailer can be asked to show the data plate on the appliance. A data plate is illustrated in Figure 4-4 and it contains two major indications of gas certification, the certification badge or label and the certificate number. However, if buying a gas appliance online, the Certification certification information observed in Figure 4-4 can be verified by asking the provider. Number
Warning Label Certification Number
Warning Label
Certification label or badge
Figure 4-4: Typical Appliance Markings: (Information Data Plate including certification number, warning and certification label)
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Section 5: Consumer Safety Awareness 5.1. Gas Retailers’ Safety Awareness Plans (SAP) As of 1 February 2013, following the changes that were made to the National Energy Retail Law (South Australia ) (NERL), a NERL gas retailer must prepare, maintain, publish on its website and periodically revise a SAP in accordance with the requirements of Regulation 36A of Gas Regulations 2012.
The requirements prescribe that the SAP must include details of the retailers’ consumer communication plan, including topics ranging from general gas safety information, to the gas appliance safety approvals scheme, and who to contact in the event of a gas supply outage. The NERL gas retailer must obtain the approval of the Technical Regulator to the SAP and any revision.
The retailers submitting SAPs for 2014/15 were AGL South Australia Pty Limited, Origin Energy Retail Ltd, Energy Australia Pty Ltd and Simply Energy. Following a review of the SAPs, the Technical Regulator approved the plans.
5.1.1. Continuous Safety Promotion
Proactive awareness campaign The Be Energy Safe Campaign continued through the financial year 2014/15. This campaign aims to promote gas safety to the community by raising awareness of gas safety and influencing the general public to take the appropriate action. There are three components to this promotion. It is done by advertising on Google and Facebook as well as by short 10 second “grabs” during the radio traffic reports. The Technical Regulator and the Corporate Communication Group (CCG) developed the program and the CCG implemented the program through an external service provider MEC Interaction Adelaide (MEC). Reports were provided regularly to inform the Technical Regulator on the rate of penetration of the advertisements and thus providing a grading for this. Overall the grading is considered to be fair. Some examples of the Facebook advertisements are shown below.
Figure 5-1: Example of Facebook advertisements Some of the important messages conveyed were: CO2 awareness – do not bring outdoor gas appliances indoors – service your appliance regularly; Gas leaks should be reported via the gas leak number 1800 GAS LEAK; Gas and electrical jobs should be done by licenced gas fitters / electrician – they are not DIY businesses; Gas and electrical works should come with a Certificate of Compliance; Barbecues should be serviced regularly to prevent gas leak; Safety switch should be tested twice a year; Christmas light should be checked for faults prior to being used.
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Table 5-1: Be Energy Safe campaign statistics
Publisher Summary Impressions Clicks CTR
GDN 11,713,937 29,774 0.25% Search 85,379 1,238 1.45% Facebook 15,991,120 15,881 0.10% End of campaign figures have come in at 27.8m impressions served with 46.9k clicks and an overall Click Through Rate (CTR) of 0.17%. CTR is the number of users that click on a specific link out of the total users that view a page, email, or advertisement. The overall CTR of 0.25% for Google Display Network (GDN) is considered to be a good result for text advertisements. With Facebook, a total of 316,000 people were reached and the CTR was typically around 0.10%, which is also an encouraging result. It was observed that more people were engaging with the advertisements through the year as a result of internal improvements on how advertisements were run and automatically optimised. On Google, the most frequently accessed campaign messages were:
Gas Leak (7579 clicks); Christmas Lights (5897 clicks); Carbon monoxide (2351 clicks); Powerline Safety (1830 clicks); Licenced Tradespeople (1473 clicks).
On Facebook, the most frequently accessed campaign messages were:
Gas Leak (3421); Carbon Monoxide (3271); Don’t DIY get a licenced tradesperson (2392); Buy certified appliances (1961); BBQ Safety (1541).
Reactive awareness campaign The Technical Regulator also provides a reactive safety awareness promotion. This usually takes the form of a single or series of media releases around the topic of interest. Typically, this occurs when a particular gas related incident occurs and it allows the Technical Regulator to ensure that the public receives the appropriate safety information.
5.1.2. The Technical Regulator Website Information about the Office of the Technical Regulator (OTR) can be found at the following location, www.sa.gov.au/otr for technical information and www.sa.gov.au/energysafe for consumer safety information for gas and electricity. The OTR web content is regularly updated as technical regulation and safety issues change or occur.
In 2014/15, there were approximately 146,594 visitors to the OTR web content, of which nearly 65% were new visitors. The number of pageviews reached 291,984. On average, users of OTR content looked at two pages per visit and spent just under two minutes engaging with that content. Of the visitors to the site, 84% were from Australia and of those, 51% were from Adelaide.
The number of visitors to the site per month almost doubled in March 2015, which corresponded to a safety issue relating to portable butane gas stoves. Although visitors per month have since decreased, they continue to remain higher than in 2013/14.
115,789 unique visitors to the OTR web content on sa.gov.au.
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Figure 5-2: Google statistics for the OTR website Table 5-2: Legend
Name Definition Sessions Total number of visits to your site Unique Visitors Total number of first time visitors to your site Pageviews Total number of pages viewed on your site Pages / Session Average number of pages viewed per visit Avg. Session Duration Average visit length of all visitors Bounce Rate Percent of single-page visits % New Sessions Percent of total visitors who visited your site for the first time
The top three pages visited on the OTR website for 2014/15 were:
Electricity and gas safety for consumers (29,892); Contact the OTR (12,774); Electrical, gas, plumbing and technical regulation (7,341).
The top five OTR – Gas pages visited for 2014/15 were:
Portable butane gas stove safety (10,836); Reporting gas leaks (5,227); Carbon monoxide safety and awareness (5,080); Gas Acts, Regulations and Standards (4,493); How to turn your gas supply on and off (4,405).
5.2. Gas Consumer Safety Survey For 2014-2015, Harrison Research was contracted to conduct the annual telephone survey of the Technical Regulator to gauge domestic gas consumers’ experience with gas safety. This survey was conducted as a computer assisted telephone interview. A total of 400 households connected to gas (either reticulated Natural Gas or LP gas, or through LP gas cylinders) were interviewed. Amongst these 400 households, 300 were located in the Adelaide metropolitan area and the remaining 100 in SA regional areas. Given the length of the survey in previous years, the survey script was reviewed and shortened significantly which allowed a reduction in running cost for this survey and provided the opportunity to interview more households that were connected to gas.
Key outcomes from the 2014-2015 Consumer Survey The 2014-2015 Consumer Survey key outcomes were:
Awareness of the Office of the Technical Regulator and its function stood at 19%; About 86% of the survey respondents stated that they were aware of the dangers of CO, principally because you cannot smell it (69%), it is highly toxic (33%) and you cannot see it (21%);
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When asked who is responsible for the maintenance of on-site service installation or any appliance within the property connected to that service installation, results were, the owner (59%), the network operator (30%) and the company sending the bill (20%); Amongst those who had gas work done in their property in the last 2 years (27%), virtually all (99%) were aware that the person undertaking the job should be licenced and qualified, Then 91% said that the person was licenced and qualified, 64% were aware they should receive a certificate of compliance when gas work is done and 60% received one when they had a job done; A small proportion of the public is buying appliances online (7%) (mainly electrical appliances); In relation to reporting unsafe situations, the top three answers were: o For Electricity: SA Power Networks, the billing company and an electrician; o For Gas: the billing company, triple zero and Australian Gas Network; o For Plumbing: a plumber and SA Water. About 14% of those surveyed could recall seeing or hearing any safety promotion relating to electricity, gas or plumbing, which was considered as an encouraging result for the advertising campaign. The main messages recalled were: o Dial before you dig (15%); o Safety around powerlines (13%); o BBQ safety and servicing (10%). Out of the 14% recalling the advertisement, 15% said that the promotion encouraged them to seek further information; One in five (20%) of those surveyed indicated that they had their gas installation and appliances serviced (when asked specifically about BBQ, only 13% indicated that they have it serviced); The majority of those surveyed (95%) said they could recognise the smell of gas and 27% indicated that they had previously reported a gas leak.
Compared with last two years surveys, recognition of the smell of gas was about the same. However awareness of dangers of CO was down from 96% to 86% this year. Regardless of that result, the Technical Regulator is encouraged by some of the findings while being satisfied with the majority. It is especially apparent that more people recalled seeing the advertising campaign this year and more people also indicated changing their behaviour after seeing the safety promotion.
This study continues to help the Technical Regulator to reinforce the advertising campaigns, website and any other useful tools to inform the public about the key safety information with regard to gas and its use.
Where relevant, the Technical Regulator can provide any sections of the survey report available to natural gas and LP gas entities, upon request.
The results of the consumer survey emphasise a need to continue to remind the public about the following key safety requirements:
ensure you are provided with a certificate of compliance from their licenced gas fitter, electrician or plumber upon the completion of any installation or maintenance work; regular maintenance of your gas appliances should not be overlooked; and the danger of Carbon Monoxide (CO) should be emphasized as it is a subject of great concern for public safety when using gas appliances indoors.
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Section 6: Gas Supply Emergency Management The gas supply in South Australia is sourced from three states: South Australia, Victoria and Queensland and as mentioned in section 1, there is now an active interconnection between northern and southern gas supplies via Pelican Point power station. This diversity of sources helps to ensure the security of supply to South Australia.
Figure 6-1: The city gate odorising, gas metering and pressure reduction compound that feeds natural gas to the Port Pirie Township and local industries. In 2014/15, there was only one major gas supply incident that interrupted supply to a significant number of consumers. This incident involved a rupture of the Epic Energy South Australia (EESA) major transmission pipeline that feeds the northern regional areas of Port Pirie, Whyalla and Port Bonython. A further description of the Technical Regulator’s involvement is provided in the case study (see next page). However, this incident affected approximately 10,000 consumers and included the two major industrial consumers, Nyrstar in Port Pirie and Arrium (formerly One Steel) in Whyalla and the respective townships, hospitals and aged care facilities.
The overall gas outage lasted for five days while repairs were undertaken by EESA with the gas supply to Port Pirie being lost completely and parts of Whyalla and Arrium preserved during this period. The gas network distributor AGN and their network operator APA Group made the distribution networks safe and provided compressed natural gas to the respective hospitals and aged care facilities. As the incident progressed, AGN and APA Group took the innovative step of setting up and injecting natural gas into the Whyalla township that was supplied from a liquefied natural gas (LNG) tanker. This was the first time that this had been attempted for a distribution network in South Australia and it could lead to future expansion of this type of gas supply in the state. It should be noted that the cause of the pipeline rupture is still under investigation and that it has meant that there are some operational restrictions affecting the pipelines operating capacity in place.
The Technical Regulator has the responsibility to assess and monitor any threatening situations and is prepared to manage an emergency should one occur. Should an event occur, normally the Short Term
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Trading Market (STTM) for gas would be the first line of defence in managing any shortfall. If the shortfall is not resolved, the Technical Regulator would consider recommending that the Minister issue directions for temporary gas rationing. The following case study highlights some of the Technical Regulator’s activities during a gas supply incident.
In April 2015, the Technical Regulator received a notification from APA identifying a pressure drop in the gas distribution network in Port Pirie. At that point the cause of the pressure drop was unknown but it could potentially impact on gas supply to all consumers in Port Pirie (more than 5,000). APA was in the process of mobilising essential staff to their depot at Kidman Park to organise an appropriate response. Given the nature and the potential of this incident to cause major gas supply interruptions to the area, the Technical Regulator immediately contacted Epic Energy South Australia (EESA) to see if there was a transmission pipeline issue involved. It was then that EESA reported that the Whyte Yarcowie to Port Pirie lateral pipeline had ruptured near the township of Gladstone. At that stage, very little was known about what had actually happened and what would be the extent of the impact upon the local gas supply. Once the extent of the problem was identified the various stakeholders went about initiating their respective emergency plans and it was realised that up to 10,000 consumers had been affected in both Port Pirie and Whyalla. For the Technical Regulator, this meant communicating with all of the stakeholders and developing a picture of what had happened, the extent of the likely impact upon supply and the resilience, if any of the impacted systems. The Technical Regulator held discussions with Arrium regarding modifying the steel makers gas usage pattern until the supply was returned to “normal“ and with EESA about its ability to keep Whyalla “alive”, given that Port Pirie had already lost supply. In addition, the Technical Regulator maintained regular discussions with AGN and APA Group regarding their activities in trying to preserve some gas in and maintaining the safety of the gas network in Whyalla. These discussions extended to assistance in getting both Port Pirie and Whyalla safely back on line with natural gas and included important communication with Safework SA regarding the use of liquefied natural gas (LNG) in Whyalla. As in all incidents of this type, the Technical Regulator was advising the Minister and the Department of State Development (DSD) executives in case there was a need for the Minister to implement any temporary gas rationing. The Technical Regulator was also kept informed on the progress of the investigation and of the potential impact on the gas supply that might arise through any actions taken by EESA as a result of the investigation.
All of the respective producer, pipeliner and gas distribution gas entities carried out a number of emergency exercises during 2014/15. These exercises dealt with and tested procedures to manage the various potential problems that may occur within the gas supply chain in South Australia.
LP gas in South Australia is primarily supplied from Port Bonython by Santos, which provides approximately 80 per cent of the SA market with the remainder supplied from interstate. The market is generally made up of autogas for vehicles and propane for heating.
Over the last 12 months there have been no major incidents that affected the supply of LP gas in South Australia.
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Section 7: Regulatory Coordination 7.1. Safety and Technical Standards The Technical Regulator is actively represented on the relevant Australian Standards committees and joint Australian and New Zealand Standards committees that deal with gas issues and plays an important role in developing and maintaining the Standards.
These technical Standards define the minimum requirements for the design, installation, commissioning, operation, maintenance and decommissioning of gas infrastructure, installations and appliances and ensure that the gas distribution networks are being operated with a high level of safety and reliability. The Standards also address the quality of gas supplied.
7.2. Committee Representation The Technical Regulator is represented on or has provided valuable technical comments to several Standards Australia committees as well as many other committees, forums and associations.
The Technical Regulator has been, and continues to be, directly involved in the development and promotion of a number of industry technical Standards. Several staff members represent the Technical Regulator on the key Standards committees. The resultant Standards are called up into legislation administered by the Technical Regulator. This provides the way forward in setting the minimum technical and safety requirements and a principle to ensure appropriate safety enforcement. The Technical Regulator represents the GTRC on the two key committees:
7.2.1. AG-006, Gas Installation Committee (AS 5601) The purpose of the committee is to maintain Part 1 Gas installation- general installations and Part 2 LP gas installations in caravans and boats for non-propulsive purposes. The recent activity in amending these documents is as a result of new innovations and changes to building and work practices, to materials and to appliance technology.
This Standards committee is a gathering of industry subject matter experts representing industry stake holders, i.e. technical regulators, appliance manufacturers, gas suppliers, utilities / network operators, installers, trainers, and industry bodies such as the master plumbers association, the plumbing industry commission and the Australian Building Construction Board (ABCB).
The Technical Regulator is able to communicate information to and from the industry stake holders (e.g. the trade and GTRC) and Standards Australia to ensure that their views are represented in the development of the Standards.
7.2.2. AG-001, Gas Appliances Committee The purpose of the committee is to develop a new series of gas appliance Standards and to maintain the entire suite of gas appliance Standards that are within the committee’s scope. These Standards cover the technical, safety and performance requirements of domestic and light commercial gas appliances, known as Type A gas appliances.
The committee has recently introduced the concept of a new series of Standards known as the AS5263 series of Standards. These Standards are being developed in an attempt to avoid the need to provide a new Standard for every new gas appliance that comes out on the market. They concentrate on the fundamental safety principles of all gas appliances especially things like combustion and temperature hazard requirements and relate them across all gas appliances.
It is now to become a joint project with New Zealand and will result in the soon to be published AS/NZS 5263 series of Standards. The Technical Regulator has made a major contribution to this process and the changes that it will make in the gas appliance certification process in the future.
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As already mentioned, the Technical Regulator participates on the AG 006 Gas Installation and the AG001 Gas Appliance Standard committees as a representative of the GTRC. These committees convene periodically throughout the year to consider submissions from the gas industry including their membership to amend or revise their respective Standards. This is often brought about in an effort to reflect the dynamic changes brought about by new technology in appliances, installation materials, or building practices resulting from energy efficiency requirements and the interactions caused by these changes. As an example, with higher energy efficiency building Standards mandated for construction this has reduced the level of natural ventilation in new dwellings. Having less natural ventilation puts pressure on the quality of the air available for the occupants and for the correct operation of the gas appliances. This is further detrimentally affected in the presence of some mechanical air extraction systems. Typically a new energy efficient home will be well sealed to prevent energy and heat loss and it is possible to create a negative pressure indoors when an extraction fan or range hood is operated. This is particularly crucial if there is insufficient make up air to balance the air pressure with that of the outside environment. This situation can adversely affect flued gas appliances and cause spillage of combustion products into the occupied areas as the flue system reverses flow in order to supply the makeup air in the living space. This scenario occurred in Victoria in 2010 in a well-sealed house where the toilet light/exhaust fan was operated as a night light. This caused a negative pressure within the house and that resulted in the spillage of combustion products into the house from the adjacent operating gas space heater. As the combustion products accumulated within the living space the oxygen levels were reducing over time. This resulted in a change in performance of the gas space heater where it was undergoing incomplete combustion and producing increased levels of carbon monoxide (CO). The occupants of the house were asleep at the time and unfortunately two children succumbed to CO poisoning. This tragedy brought about a complete review of the ventilation requirements by the gas installation standard committee and industry stakeholders. As a result of this the commissioning procedures for all gas appliances to be installed indoors have now changed to incorporate “air current spillage testing”. This is used to ensure that the local environmental circumstances do not pose a risk or danger to the safe operation to the gas appliances and consequentially, the consumer. The spillage test has also been carried over to servicing appliances to ensure that exhaust fans cannot interfere with the appliance flue operation. It also created a major national CO awareness campaign by the members of the GTRC, with the objective of making consumers aware of the risks of CO poisoning and to encourage regular maintenance of gas appliances and installations.
7.2.3. AG-008, Gas Distribution Committee (AS/NZS 4645) In 2014/15, the Technical Regulator contributed to the joint Australia and New Zealand Standards Gas Distribution Committee (AG-008) and provided input in developing further revisions to some parts of the Australian/New Zealand gas distribution Standard AS/NZS 4645: 2008 Gas distribution networks.
The intent of this Standard is to provide for the protection of the general public, the gas distribution network and the operating personnel as well as the environment, and to ensure safe and reliable operation of gas distribution networks that reticulate gas to consumers.
7.2.4. AG-010, Natural Gas Quality Specifications Committee (AS 4564) The function of AG-010, the Gas Quality Specification Committee, is to maintain the AS 4564:2011 Specification for general purpose natural gas. This specification sets out the gas quality requirements necessary to ensure the safety of general-purpose natural gas transported and supplied for use in natural gas appliances and equipment, and for use as fuel in natural gas vehicles.
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7.2.5. Gas Technical Regulators Committee (GTRC) All Australian jurisdictions as well as New Zealand are members of the Gas Technical Regulators Committee (GTRC). The GTRC held two meetings during 2014/15.
Issues featuring highly included the revision of the combined Australian / New Zealand version of the gas installation standard (AS/NZS 5601), a national response to gas appliance safety issues and the improvement of the national Australian gas appliance testing and certification regime.
The Technical Regulator maintained close communications with interstate safety regulators through both the formal GTRC channels and informally with peers in those organisations to share technical knowledge, information on appliance safety issues, common interests and concerns. These relationships are vital to ensure that technical expertise is maintained in all areas covered by technical regulation.
An ongoing example of an area of common concern and cooperation between interstate gas regulators is the issue of uncertified gas appliances offered for sale on internet auction sites. Regulators have continued to send out warning letters to the appliance retailers and the internet website agents to warn of this potentially misleading practice.
The GTRC is also monitoring the performance of a number of appliance that are considered to exhibit a higher risk of safety issues these include canister cookers and area heaters.
The GTRC has also been monitoring issues associated with carbon monoxide poisoning and the individual jurisdictional response to issues surrounding the risks associated with gas appliances and carbon monoxide.
CO mitigation strategy In May 2010, Chase and Tyler Robinson, aged 8 and 6, died from carbon monoxide poisoning from a faulty gas heater in their home. The cause was found to be a gas heater that was producing carbon monoxide because it had not been properly serviced and maintained.
In July 2011, the GTRC provided a draft strategy, the conclusion of which was that a CO awareness campaign was likely to provide the best outcome to this problem at a sustainable cost. The Technical Regulator continues to have a major CO awareness strategy. It is contained on the “Be Energy Safe” website located at sa.gov.au/energysafe. The website emphasises the need for correct room ventilation and regular gas appliance maintenance as well as only using appliances for what they are designed to do (i.e. do not use appliances that are designed for outdoor use inside your home).
It should be remembered that if gas does not burn correctly CO is produced. CO is a colourless, odourless and tasteless gas which is very poisonous and the human body doesn't recognise its presence. Given these properties it can kill and hence it is often called 'the silent killer'.
7.2.6. Other Committees, Forums and Representation The Plumbing and Gas Fitting Advisory Forum; The Australian Institute of Energy: The Technical Regulator has membership in this organisation to stay informed about activities being undertaken across the energy industry; Gas Energy Australia: The Technical Regulator has membership in this organisation to stay informed about development in the LP gas, compressed and liquefied natural gas industries; River Murray Houseboat Hirer’s Association: The Technical Regulator liaises with the association and provides technical and safety information relating to LP gas installations on houseboats; Plumbing Industry Technical Forum: The Technical Regulator provides advice on legislation and Standards relating to natural gas and LP gas installation and appliance safety;
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Caravan and Camping Association of South Australia (CCASA): The Technical Regulator provides advice and technical assistance to ensure that gas installations and appliances comply with technical and safety standards; Domiciliary Care and Royal District Nursing Society (RDNS): The Technical Regulator provides advice with respect to making installations and appliances safe where elderly, infirm or blind people are involved or where the householder may suffer from dementia; National Gas Industry Training Package: In 2014/15, the UEG06 Package (training package for workers employed by, or contracting to, gas distribution companies to work on their infrastructure) was again reviewed and further changes were proposed for endorsement as part of continual improvement; SafeWork SA: SafeWork SA is responsible (under the Dangerous Substances Act 1979) for the storage and handling of LP gas, where the quantity stored on site exceeds 560 litres. The Technical Regulator Gas Installation and Appliance section and SafeWork SA have excellent two way feedback with respect to safety, installation and storage facilities.
SafeWork SA also works closely with the Technical Regulator when investigating workplace safety accidents where natural gas or LP gas are involved.
Gas Technical Advisory Committee (GTAC) Pursuant to Section 16 of the Gas Act 1997, the Technical Regulator established the Gas Technical Advisory Committee (GTAC). The committee membership for the year included:
The Office of the Technical Regulator, the Plumbing Industry Association, CEPU Plumbing Division, Office of Consumer and Business Affairs (now Consumer and Business Services) (CBS), Senior Gas Lecturer, TAFE Regency Park, Envestra Ltd, APA Group, Elgas and Origin LP Gas.
In 2014/15 the Technical Regulator held two GTAC meetings during which various issues in relation to the monitoring and regulation of safety and technical standards in the gas supply industry and issues relating to gas installations and gas appliances (including proposed legislative changes) were discussed. Following a government wide review of boards and committees, the GTAC is to be combined with the Electrical equivalent.
National Gas Emergency Response Advisory Committee (NGERAC) The Ministerial Council on Energy (MCE) has developed a National Gas Emergency Response Protocol. The Protocol contains two main elements:
Arrangements for inter-jurisdictional consultation on the use of statutory emergency powers in the event of a major natural gas supply shortage; and Establishment of a government-industry National Gas Emergency Response Advisory Committee (NGERAC).
The Protocol provides for NGERAC to regularly meet, conduct simulation exercises, develop protocols for communication during emergencies and plan for emergencies including developing curtailment tables and options.
The NGERAC met twice in the 2014/15 financial year. Outcomes from these meetings included:
The development of scenarios for the 2015 Contingency Planning Report and the inaugural activation exercise; discussion of gas sharing principles; agreement to the Contingency Planning Report; review of the activation exercise (March 2015); Progression of the review of the 2005 Memorandum of Understanding.
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NGERAC conducted its first activation exercise in March 2015 to test its protocols in a Level 3 incident (a major gas supply emergency impacting two or more jurisdictions). Observations from the exercise included the need for greater clarity in the NGERAC Incident Levels, the requirement for modelling of minimum gas supply to maintain systems integrity and security and to maintain essential services, and stronger governance processes for emergency teleconferences. Recommendations from this exercise will be included in the 2015/16 NGERAC work plan.
NGERAC contracted the Australian Energy Market Operator (AEMO) to develop the 2015 Contingency Planning Report which updated the 2013 Report’s scenarios, the Eastern Australian natural gas pipeline system and included a new scenario to reflect the significance of Queensland Liquefied Natural Gas (LNG) production. The Report highlights only two scenarios that would require NGERAC action: the loss of all Longford gas plants particularly in the shoulder and winter periods; and the total loss of Moomba while it is supplying the Queensland LNG trains. These two scenarios will form the basis for including modelling of minimum gas supply requirements to maintain systems security and to maintain essential services in a jurisdiction in the 2015/16 NGERAC work plan.
Short Term Trading Market (STTM) A Short Term Trading Market (STTM) for gas commenced operation in September 2010 at hubs in Adelaide and Sydney and is operated by AEMO. In December 2011, a further STTM hub commenced operation in Brisbane. The purpose of the STTM is to provide price signals to the gas market which will, in the long term, assist in the provision of further gas supplies and infrastructure. This will help to ensure long term gas supply security. The STTM also operates a contingency gas market should gas supplies fall short of the estimated daily demand. The use of the contingency gas market will extend the use of market outcomes and may delay the need for temporary gas rationing.
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Appendix 1. OTR Background A1.1. OTR Organisational structure and Gas branch
Minister for Energy
Technical Regulator Gas Act 1997 Electricity Act 1996 Energy Products (Safety and Efficiency) Act 2000 Water Industry Act 2012
GAS ELECTRICAL PLUMBING and Gas Act 1997, Electricity Act 1996, WATER Energy Products Energy Products INFRASTRUCTURES (Safety and (Safety and (Water Industry Act Efficiency) Act 2000 Efficiency) Act 2000 2012)
Liaison with ESCOSA, Energy Industry Gas Gas Ombudsman, Australian Emergency Infrastructure Installations Energy Regulator, Planning and Safety and and Appliance Australian Energy Market Management Reliability Safety Operator and the Gas Supply Industry on gas. Administer the Gas Act 1997and Energy Products (Safety and Efficiency) Act 2000 and Regulations
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A1.2. Technical Regulator’s activities and monitoring
South Australian Government/Parliament
Office of the Technical Regulator
Gas Act 1997 and Gas Regulations 2012 and Energy Products (Safety and Efficiency) Act 2000
Gas Production, Gas Distribution Gas Retail Consumers – Residential, Small Appliance and LP gas Power Generators, Storage and Gas Networks Entities Business and Industrial Supply and Transmission Commercial, Industrial and Industrial Equipment Installations Networks Domestic
Gas Installations GasIndustry Gas quality Public safety Assistance to Public safety Connections Appliance Public safety Emergency Security and ESCOSA and Investigation Compliance with approvals Security and management reliability of supply EWOSA where of incidents standards Appliance reliability of requested Security and Gas quality and Gas Certificates certification supply Consumer complaints reliability of Emergency of Compliance Appliance Gas quality Safety supply management Technical Inspections and recalls Emergency Awareness advice on Standards Safety, Reliability, approvals of Monitoring of management Plans appliances development residential, appliance Safety Maintenance and Technical Safety surveys commercial and manufacturers Management Management Public industrial and retailers Plans installations
Plans education Technical Gas OTR OTR Gas Measurement Auditing of Technical advice advice Certificates of Management retail outlets on use of gas, Investigation Compliance
Activities and licensed gas Major Plans and mobile of incidents Technical workers and Compliance audits LPG and advice equipment contractors complaints Investigations of Compliance Investigation of incidents and Standards audits incidents and technical development complaints Investigation complaints of incidents Standards Standards and development development complaints
Residential, Small Industry and Gas Appliance and Indoor and Outdoor General Other States Business and Power Industry Component Environment and Public and Countries
Beneficiaries Industrial Consumers Generators Employees Manufacturers, Suppliers Greenhouse
and Retailers
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Appendix 2. Certificate of Compliance
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Appendix 3. Presentations The Technical Regulator provides information about Standards to gas fitting contractors, architects and engineers, as well as to commercial and industrial users of gas. Many of these enquiries involved site visits as well as significant research. Refer to table A3.1.
Presentations were also provided to non-technical groups; generally about the safe use of LP gas in temporary kitchens at outdoor events. Refer to table A3.2 for further detail.
Table A3-1: Technical Presentations
TECHNICAL PRESENTATIONS
Gas contractors ( AS/NZS 5601 Standard) 13
TAFE/PEER TECH/Training Prospects lecturers 3
Housing Industry Association 1
Housing SA Housing Improvement Branch 1
Master Builders Association 1
Australian Hydraulic Services Consultants 1 Association of SA
Total 20
Table A3-2: Presentations for Community Groups and Event Organisers
NON GAS INDUSTRY PRESENTATIONS
Royal Adelaide show committee 1
Clipsal 500 Project Managers 1
Carnevale 1
The Unley Gourmet Gala 1
Schutzenfest 1
Spotless Facilities Management 1
Caravan and Camping Show 1
Adelaide Fringe Festival 1
Oz Asia 1
Garden of Unearthly Delights 1
WOMAD 1
Total 11
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Appendix 4. Operating Statement
Operating Statement for the year ending 30 June 2015 In the 2014/15 financial year, ending June 30, pursuant to Section 24 of the Gas Act 1997, licence revenue received for gas amounted to $1.857 million. This was used to recoup the recurrent costs of the Gas section of the Office of the Technical Regulator. Total recurrent costs for the year amounted to $1.753 million. After allowing for other income there was an operating net surplus of $0.104 million which was transferred to equity.
Operating Revenues $
Licence Fees 1,857,000 Expiation Fees 0 Other Income 65 TOTAL OPERATING REVENUES 1,857,065
Operating Expenses
Salaries and Wages 1,151,648 Goods and Services 601,051 TOTAL OPERATING EXPENSES 1,752,699
TRANSFER TO EQUITY 104,366
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Staffing Numbers The number of full-time equivalent (FTE) energy regulatory staff for South Australia is shown in the table below. These numbers have been split into the two sections of the Gas branch of the OTR. Table A4-1: FTEs in the Electrical Section of the Technical Regulator’s Office
FTEs in Installations FTEs in Infrastructure Total FTEs & Appliances
3 5.6 8.6
Resource Efficiency The ratios of the total population in South Australia to the office operating expenses are shown in the figure below. The OTR has operated efficiently whilst ensuring public safety and keeping costs to a minimum. As can be observed from the following graph, the energy regulatory costs are being maintained at a low level, indicating an efficient use of resources.
Office of the Technical Regulator - Resource Efficiency 1.1
1
0.9
($/population) 0.8
0.7
2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 Operating expenses per SA population population SA per expenses Operating Year
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Appendix 5. Network Performance 2014/15 Key Performance Indicators (KPIs) for the distribution networks, as supplied by Australian Gas Networks, owner of the distribution networks in South Australia, and APA Group, operator of these networks, are as follows:
KPI Section Aspects measured
1. Safety Network and public safety
Accuracy and reliability of gas metering and 2. Measurement measurement of gas heating value
3. Quality Natural gas quality
4. Reliability Reliability of gas supply and equipment
Safety and soundness of customer connections to the 5. Connections pipeline network
Key Performance Indicator 2010/11 2011/12 2012/13 2013/14 2014/15
1. Safety
1.1 The maintenance of continuous, reliable gas supply
Number of over pressurisation 2 1 3 0 1 incidents in networks per year
Number of complaints of poor 2 12 21 63 69 supply pressure
Number of gas outages 5 20 11 17 15 (>5 consumers affected)
Regulator failures (including active failures) and number of instances 1 0 1 0 0 of above Maximum Allowable Operating Pressure.
1.2 Instances of third party damage
Number of times damage occurred to the mains and services, caused 796 714 741 667 672 by third parties
Number of transmission main 0 0 0 1 0 damage or near miss reports
1.3 Dealing with potential accidents or unsafe situations
Emergency plan exercises 6 6 5 7 5
Revised Revised Revised Revised Revised Emergency plan updates 10/2010 10/2010 01/2013 01/2013 02/2014
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Key Performance Indicator 2010/11 2011/12 2012/13 2013/14 2014/15
Number of evacuations 4 23 1* 2* 1* *The number is lower compared to 2011/12 due to the clarification of definition of evacuation (to reflect only where there is a high risk or fire or explosion)
Number of instances where a gas leak from a network enters a 5 5 2 2 0 building
Number of incidents relating to a 113 84 6* 6* 3* gas leak involving the attendance of a fire brigade and/or emergency services *The number is lower compared to 2011/12 due to the clarification of definition of attendance of fire brigade and/or emergency services (to reflect only incidents where there is a high risk or fire or explosion)
Number of fires caused by a gas 0 2 2 3 1 leak from a network
2. Measurement
2.1 Meter retest to indicate response to customer requests and confidence in meters and meter plan and regulations
Customer retest request response 8 8 16 13 23 time if exceeding 21 days
Number of requests per year 26 24 29 33 74 (number found to be outside specification) (1) (4) (10) (11) (10)
2.2 Extent to which meters are being changed over (Gas Measurement Management Plan)
Number of meters changed Domestic 24,316 20,243 21,434 30,663 30,277 Industrial/commercial 547 648 817 1277 1485
Number of meters tested in-house *AGN did not complete any meter in-testing 1,416 695 459 36 0* of used meters
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Key Performance Indicator 2010/11 2011/12 2012/13 2013/14 2014/15
2.3 Accuracy of meters tested in-house (as returned from field)
Percentage of meters within ± 2% 91.4% 95.25% 80.2% 66.7% N/A^ ^AGN did not complete any meter in-testing of used meters. Percentage of meters outside ± 2.0% *In July 2012 the intest testing method was changed, explaining the higher percentage 8.6% 4.75% 19.8%* 33.3%** N/A^ for 2012/13 **The impact of very few meters now tested. ^AGN did not complete any meter in-testing of used meters. 2.4. Extent of bias of sample of meters tested
New meters +0.14% +0.01% -1.02% +0.15% +0.13%
Meters tested in-house +0.28% +0.32% -0.01% +0.09% N/A
Repaired meters +0.07% -0.06% -0.05% -0.11% +0.05%
2.5. Extent of meter interference
Number of detected instances of stolen gas *It was reported that an unusually high number was raised in March through June 2013. **This figure reflects the number of disconnections which have been raised by retailers with the reason category cited as ‘OFU’ (fraudulent use) and which have been processed by AGN. ^Previous figures reported reflected the number of the number of disconnections which 82 38 112* 458** 3^ had been raised by retailers with the service order category cited as ‘OFU’ (fraudulent use) and which have been processed by AGN. For the 2014/15 period this figure was 1405. The actual number of incidents of stolen gas should be classified as ‘unknown consumers’ (code of UNC’) which is zero. In instances where APA Group has identified meters that have been illegally bridged APA Group has disconnected these properties for safety reasons. These instances have been included as the ‘Number of incidents of stolen gas’.
3. Gas Quality
3.1. The quantity of gas entering the Distribution System
Total gas entering the Distribution 37,723 35,473 34,129 32,144 32,544 System (including farm taps) (TJ)
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Key Performance Indicator 2010/11 2011/12 2012/13 2013/14 2014/15
3.2. The maintenance of continuous, reliable gas supply
Number of poor combustion/poor 6 12 21 63 72 pressure incidents reported
Number of instances of out of 1 0 1 0 0 specification gas distributed
3.3. The specification of each type of gas entering the Distribution System
Gas specification including odorant Included Included Included Included Included
The number and type of complaints made to the Entity in respect of the detectability of gas by odour, 419** 552^ 1,145^^ 2065 1865* inadequate gas supply pressure or any other relevant matter minor complaints regarding reinstatement
**In 2010/11 some reports that were previously considered as enquires have being classified as complaints, thus, the number has further increased over 2009-10. ^In 2011/12 better data collection and the higher level of field activity, and consumer reaction to high bills contributed to the increase in numbers. ^^In 2012/13 the high level of mains replacement activities carried out on the distribution network has led to an increase in complaints. The record mains replacement carried out on the gas distribution network and more frequent interaction with the public have led to an increase in complaints in 2013/14. *Improved management of reinstatement activities as part of mains replacement led to a decrease in complaints in 2014/15 Highest percentage of the LEL, must be <20%, at which odorant can be detected LEL = Lower Explosive Limit Moomba 16.0% 12.5% 10.9% 13.7% 8.4% Co-mingled 14.6% 8.6% 9.0% 22.7%* 9.5%* South East 17% N/A 11.5% 22.7%* 13.0%* *Non-compliant data. AGN reported that this data is indicative of the test results from the one and only regional-based field operative. Further analysis of gas samples indicated accepted odorant levels in the networks. Further testing by more than one field operatives will be carried out.
4. Reliability
4.1. Description and specification of Distribution System and its components
Length of distribution system (km) 7722 7787 7836 7950 8042
4.2. Non-standard designs/systems as approved by the Technical Regulator
Approved deviations from non- conformances to prescribed 0 0 0 0 0 standards listed in Regulation 43 of the Gas Regulations 2012
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Key Performance Indicator 2010/11 2011/12 2012/13 2013/14 2014/15
4.3. Provide reliable information in respect of the total amount of UAFG lost from the Distribution System as a result of leakage or an activity referred to in Section 82(1) of the Act and to avoid unacceptable leakage of gas
Total UAFG (TJ) 1,805*** 1,744^ 1,482^^ 1,331* 1,212
*** Based on AEMO data as at 2 August 2011 ^ Based on AEMO data as at 30 June 2012 ^^ Based on AEMO data as at 30 July 2013 * Based on AEMO data as at 30 June 2014
Lost gas from leakage based on current estimated leakage rate 1,444 1,395 1,185 1,065 970 (agreed at 80% UAFG) (TJ)
4.4. The extent to which the public are reporting gas leaks – mains and inlets services
Number of public reports of leaks 3,980^ 3,652^^ 3,565* 4,684** 4,401^*
^ This number includes 1,400 public reports which were attended but where no leak was found. ^^ This number includes 1,383 public reports which were attended but where no leak was found. * This number includes 1,319 public reports which were attended but where no leak was found. ** This number includes 1,815 public reports which were attended but where no leak was found. ^* This number includes 1,687 public reports which were attended but where no leak was found Number of leaks detected by Leakage Surveys (per km of 0.28 0.20 0.09 0.08 0.15 surveyed mains)
Key Performance Indicator 2010/11 2011/12 2012/13 2013/14 2014/15
4.5. Extent of Training
Training hours per direct employee 9 10 13.5 11.9 10.6
5. Connections
5.1. Ensuring that the gas installation safe before connecting or reconnecting to the Distribution System
Number of Certificates of Compliance received on 3,212 3,551 4,155 4,379 3,644 connection of gas installation to the distribution system*
5.2. Extent of access to system as required by return
Number of consumer connections 403,301 410,708 417,224 423,463 430,244 (at 30 June each year)
Number of new connections 10,351 8,919 8,621 8,202 8,544 completed
Number of meters removed 1,750 1,700 1,709 1,658 1,761
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Appendix 6. Glossary and Abbreviations
ACCC Australian Competition and Consumer Commission
AEMO Australian Energy Market Operator
AER Australian Energy Regulator
AGA Australian Gas Association- this is a gas appliance certification body (CAB) proclaimed by the Governor
AGN Australian Gas Network Limited formally known as Envestra Limited – entity holding a gas distribution licence in South Australia
AMP Asset Management Plan
APA Group Australian Pipeline Group and other associated entities
AS Australian Standard
AS/NZS Australian or Joint Australian/New Zealand Standards
BBQ Barbecue
CAB Conformity Assessment Body
CBD Central Business District
CBS Consumer Business Services “The licensing authority in S.A”.
CCG Corporate Communication Group
CEPU Communications Electrical and Plumbing Union
CSAP Customer Safety Awareness Plan
CCASA Caravan and Camping Association of South Australia
CFS Country Fire Service
CI Cast Iron pipe
CO Carbon Monoxide
CTR Click Through Rate
‘Dial Before You This telephone (1100) and internet service provides location information on Dig’ infrastructure, such as gas pipelines, to protect these assets during excavation work
DIY Do It Yourself
DPTI Departments of Planning, Transport and Infrastructure, formerly DTEI
DSD Department of State Development
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EESA Epic Energy South Australia
ELS Environmental Land Services (Aust) Limited
ESCOSA Essential Services Commission of South Australia (responsible for licensing of gas entities)
EWOSA Energy and Water Ombudsman South Australia
FTE Full Time Equivalent – the number of full time employees who would work the same total hours being worked by a number of part time employees
GCC Gas Certificate of Compliance
GDN Google Display Network
Global Mark A gas appliance certification body (CAB) proclaimed by the Governor
GMMP Gas Measurement Management Plan
GTAC Gas Technical Advisory Committee
GTRC Gas Technical Regulators Committee
HDPE High Density Polyethylene
HIA Housing Industry and Association
IAPMO International Association of Plumbing and Mechanical Officers – a gas appliance certification body (CAB) proclaimed by the Governor
I&C Industrial and Commercial – classification of the group of larger non-domestic meters
Incident Described in the Gas Regulations 2012 as an ‘accident’; an event causing death, injury or property damage; a gas related incident is when natural gas or LP gas or their products of combustion is (or is suspected of being) directly involved
IGA Intergovernmental Agreement
In-house Testing performed by the operator, using their own facilities, such as meter testing performed at the laboratory of APA Group depot
In-testing Removal of a meter from service and test in a laboratory; if the meter is found to be satisfactory, it can be made available for re-use (if not, it will be repaired or scrapped)
JHEA Job Hazard & Environment Analysis kg Kilogram (1000 grams) – unit of mass km Kilometre (1000 metres) – unit of distance kPa Kilo Pascal (1000 Pascals) – unit of pressure
KPI Key Performance Indicator
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LEL Lower explosive limit – the minimum amount of combustible gas in air at which the mixture is flammable
LNG Liquefied Natural Gas
LP gas Liquefied Petroleum Gas
LMP Leakage Management Plan
MAP Moomba to Adelaide Pipeline
MCE Ministerial Council on Energy
MFS Metropolitan Fire Service
MRP Mains Replacement Program
NGERAC National Gas Emergency Response Advisory Committee
NERL National Energy Retailer Law
NRAH New Royal Adelaide Hospital
Origin Energy LPG Owner of five of the LP gas distribution systems within SA Ltd
OTR Office of the Technical Regulator
PJ Peta-Joule (one billion megajoules) – unit of energy
POL connection ‘POL’ is a type of valve for LP gas cylinders and the most common type in Australia. The ‘POL’ is an acronym for the company that first produced the valves, Prest-O- Lite.
PPE Personal Protective Equipment
QSN link Queensland, South Australia and New South Wales link – pipeline from South West Queensland to the Moomba gas plant in SA
RDNS Royal District Nursing Society
Regulation Bi-annual newsletter of the Technical Regulator to the gas and electrical industry Roundup
Roadshow Technical presentation by the Technical Regulator to gas fitters, provided free of charge annually in Adelaide city and regional centres
RTO Registered Training Organisation
RVMAA Recreational Vehicle Manufacturers Association Australia
SafeWork SA Formerly Workplace Services – government department that administers the Dangerous Substances Act
Safety check Commonly known, in industry, as the ‘Couple, Light and Check’ – this is the safety check performed when a gas supply is first connected.
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SAIG Standards Australia International Global-this is among other things a gas appliance certification body (CAB) proclaimed by the Governor
SAP Safety Awareness Plan
SAPOL South Australian Police
SA Power Operator of the electricity distribution network in South Australia Networks
SEA Gas pipeline South East Australia Gas pipeline: gas pipeline that supplies natural gas from Victoria to Adelaide
SESA South East South Australia pipeline: a lateral gas pipeline off the SEA Gas pipeline that supplies natural gas to the Mt Gambier region
SRMTMP Safety, Reliability, Maintenance and Technical Management Plan
Standards Standards are either Australian or joint Australian and New Zealand standards, as issued by Standards Australia (or previously published by Australia Gas Association).
SWMS Safe Work Method Statement
SWQ South West Queensland
STTM Short Term Trading Market
TGC Tamar Gas Certification
TJ Terajoule (one million megajoules) – unit of energy
Type A Mass produced, gas appliances, primarily domestic appliances, which are pre- certified by testing prior to sale and installation
Type B Gas appliances, primarily industrial appliances, which must be certified on site to AS 3814
UAFG Unaccounted for gas – difference between the quantity of natural gas measured into the network and the quantity measured out at consumers’ meters; the difference may be due to leaking gas, differences in meter reading times, meter inaccuracy, gas theft, line pack differences and gas lost during commissioning of pipelines
UPS Unprotected Steel pipe
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