Supplemental Materials Related to NTSB's Jan. 2021 Meeting | Atmos Energy

Supplemental Materials Related to NTSB's Jan. 2021 Meeting

Click here to view our statement regarding NTSB findings.

The NTSB held a public hearing to determine the probable cause of the natural gas explosion in Dallas that occurred on Feb. 23, 2018. We are reviewing the complete findings and recommendations released today by the NTSB.  

We believe that the probable cause is reflected in the NTSB finding that the natural gas main was damaged by excavation equipment.  

Documents

Safety

Atmos Energy is rooted in the belief that safety is at the center of everything we do, and it is our enduring vision to be the safest provider of natural gas services. Our commitment to safety guides every decision we make because the safety of our employees, customers, and communities is essential. Because safety is our number one priority, we continually innovate and advance employee training, communicate safety messaging to our customers and communities, and invest in the modernization of our system. Our Party Submission contains numerous improvements that Atmos Energy has undertaken, including:

Atmos Energy has been and will continue to be a champion for damage prevention.  Our third party damage rate continues to outperform the industry average. In fiscal year 2019, the number of third party damages on our system decreased by almost 5 percent, even though the number of line locates increased by 9 percent.  To further reduce third party excavation damage, Atmos Energy:

  • Audited more of our third party line locating services to determine what actions can be taken to further reduce third party excavation damage.    
  • Strengthened our ‘Watch and Care’ program to require additional follow-up with excavators who have called in a line locate ticket. 
  • Started flagging and/or marking the location of newly installed pipe and associated facilities to bring immediate visibility to their location while our facilities map records are updated. 
  • Added new reporting metrics to better evaluate the performance of our damage prevention program.
  • Implemented a Damage Prevention Ambassador Program that encourages employees to proactively stop by excavation sites to provide damage prevention materials to excavators and ensure proper 811 notification. 
  • Is on pace to complete the roll out of LocusView so that by the end of March 2021 all distribution construction crews (internal and contractors) can capture and transmit detailed data on new pipe installation through a mobile app.  This includes as-built maps, tracking and traceability of materials, joints and associated information.  LocusView’s high accuracy GPS creates as-built maps that are integrated directly into Atmos’ GIS.   
  • Developed safety mascots and ambassadors Gus the Gopher and Rosie the Skunk to engage customers and the public in remembering to call 811 before you dig and using your senses to detect natural gas.  In 2018, our "Gus the Gopher for Call 811" won top video in the external category of the American Gas Association Safety Awareness Video Excellence awards. 

In order to better understand and address geological and climatological threats to our operating system, Atmos retained a geotechnical engineering firm which has resulted in: 

    • The development and implementation of a geological risk factor that was included in the 2019 Mid-Tex division risk analysis. 
    • The development of a geological risk factor across the state of Texas and other seven states of our operation. 

We regularly review and revise our procedures as we continue to learn from our own experiences and those of others in the industry.  Internal subject matter experts (SMEs) participate in the review and development of these procedures.  Our leak survey and leak investigation procedures have been updated to include: 

  • Mandatory 911 notification when a probable or existing hazardous condition is discovered and if first responders are not already on-site.
  • The establishment of a Safety Perimeter when a probable or existing hazardous condition is discovered.  
  • Included Emergency Shutdown language to our Service Procedure that was previously in our Emergency Procedures in order to reinforce Atmos Energy’s emergency responder’s authority to take appropriate actions during an emergency.  This includes controlling, reducing or eliminating the flow of gas to the location or area.
  • Atmos Energy’s emergency responders and operations leaders across all eight states were trained on the updated procedures.  The training also incorporated examples of recent industry experiences.    

In July 2015, the American Petroleum Institute (API) issued Recommended Practice 1173 (RP1173) outlining a Pipeline Safety Management System (PSMS).  This is a voluntary measure, not required by code or regulation.  The American Gas Association (AGA) recommended RP1173 for industry adoption in May 2019. 

In 2016 Atmos Energy began working with an industry leading third party expert to examine its practices in the context of PSMS.  Atmos Energy then conducted a PSMS self-assessment and gap analysis for its Virginia operations.  Afterwards Atmos Energy continued to participate in industry discussion groups and workshops to gain expertise and better understand how to develop and implement PSMS across its entire organization. 

After Feb. 23, 2018, Atmos Energy took additional voluntary and proactive measures to accelerate the implementation of PSMS.  Atmos Energy updated its initial self-assessment and again engaged its industry leading third party expert, this time to perform an enterprise wide PSMS assessment and gap analysis.  Atmos Energy has developed a roadmap and PSMS program documents to allow it to reach significant and widespread maturity across all elements of a PSMS - a task that RP1173 recognizes is a journey.  A Director level resource has been added in within Atmos Energy’s corporate structure to support this accelerated implementation effort. 

These and other efforts in support of PSMS are supported at the highest levels of the organization, with a corporate officer primarily responsible for the design, adoption, and implementation of PSMS.  The corporate Risk Management and Compliance Committee is responsible for ongoing governance and reporting to the Company’s Management Committee. 

Our commitment to the training of our highly skilled employees is evident and a tangible example of that is the Charles K. Vaughan Center in Plano, TX which opened in late 2010.  This state-of-the art, industry leading facility, serves as the technical training location for our front-line employees from across our eight-state operation.  The multi-week technical training programs are structured in a manner where the focus is on job-readiness.  To help achieve this, our employees spend approximately 20 percent of their time in the classroom and 80 percent of their time performing hands-on training.  As part of our never-ending pursuit to become the safest provider of natural gas services, employees in the field start each day with a safety meeting. As a company, we held over 91,000 hours of safety training in fiscal year 2019.

In order to enhance our robust training curriculum and for our highly trained and qualified gas professionals and our operation leaders, Atmos:  

  • Developed and delivered an online leak survey refresher training for all employees with specified leak survey Operator Qualification (OQ) requirements.
  • Developed and delivered a one-week leak survey refresher training class in the first half of 2019 to all employees whose primary job responsibilities are leak surveying.  The training consisted of classroom instruction, a review of procedures, hands-on training by equipment vendors, discussion of weather-related conditions, and industry case studies.   
  • Implemented an Operations Supervisor Boot Camp at our Charles K. Vaughan training facility that allows operations supervisors to gain a better understanding of our technical training courses, processes and equipment through a one-week hands-on experience class.  Every operations supervisor at Atmos has now completed the training, and all new supervisors will be required to attend future classes.  

Leak survey and detection is an important part of our safety efforts.  Atmos regularly performs leak surveys at more frequent intervals than required by federal regulation. In order to enhance our leak survey program, Atmos:  

  • Created a dedicated work group within the Mid-Tex division to support and monitor leak survey activity.
  • In 2019, completed a one-week refresher training class for all employees who perform leak surveys as their primary job. 
  • Continues to closely monitor our system in the Dallas-Fort Worth area through more frequent leak surveys and has employed additional third party resources to support these efforts.
  • Is conducting additional leak surveys across a broad area of the Mid-Tex system at more frequent intervals than required by federal and state regulations.      
  • Has purchased additional advanced mobile leak detection units within our Texas operations.  These units are equipped with sensors that are 1,000 times more sensitive than traditional technologies.  We plan to add additional units over time.
  • Continues to implement GPS tracking functionality on leak survey equipment.  
  • Deployed iAuditor, an electronic inspection application, to our internal and third party inspectors to drive consistency in inspection and quality management processes through performance reports, trend spotting, and the identification of actionable items.
  • Implemented an automated interface between our Operator Qualification (OQ) program and our work management system that cross-references an employee’s operator qualifications with the OQ tasks prior to assigning a work order.  This new capability replaces previous manual processes.  

We are always working with industry and technology partners to develop and evaluate new technologies to enhance safety.  For years we have partnered with the Gas Technology Institute’s Operations Technology Development (OTD) collaborative, which develops technology-based solutions for the natural gas industry.  Among the efforts that Atmos supports to enhance safety through our involvement in OTD are:

  • Residential methane detectors
  • Leak survey/investigation sensors and technology
  • Damage prevention tools and practices

Over the last 10 years, we have invested more than $11 billion company-wide to modernize our pipeline infrastructure, over 80 percent of which was allocated to safety.  Over the next five years we anticipate spending $11 billion to $12 billion and replacing approximately 5,000 to 6,000 miles of distribution and transmission pipe. We have a reasonable plan to replace all remaining cast iron by the end of 2021. Other highlights for fiscal year 2019 (Oct. 1, 2018 to Sept. 30, 2019) include:

  • 890 miles of distribution and transmission pipelines replaced.
  • 53,000 service lines replaced.
  • 288,000 hours of safety, technical, and other training delivered.
  • Implemented advanced data analytics tools which can transform, merge and analyze data sets using automated and repeatable workflows that provide faster and more precise results than manual processes.   
  • Implemented visualization technology tools that can provide near real-time graphical representation (dashboards, etc.) of data to assist operations and compliance leaders in their decision making.