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Charging for gas transportation activities: a guide

Sixth edition - April 2010

Contents

Part 2: Illustrative examples of costs recoverable activities

Introduction

This Annex sets out the activities HSE undertakes in respect of gas safety and provides information on the nature of the activities for which costs will be recovered, and where possible, indications of the resources that may be required for the assessment of safety cases, inspection, assessment, investigation and formal enforcement in the gas transportation industry.

Where an estimated time is given in the following examples it was based either on practical experience or an assessment of typical resources which may be required. For cost recovery purposes one day is equivalent to 7.4 hours. Duty holders are asked to bear in mind that these examples may not be typical of their own business and the effort expended by HSE will be dependent on the quality of the safety case submitted or the type and depth of inspection, investigation or formal enforcement required.

Acceptance of safety cases

A gas conveyor who is a licensed gas transporter installs piped distribution systems operating at low pressure only. Typically, these systems will be supplying gas to new housing estates and will be connected to Transco's or another upstream conveyor's distribution system. Assessment of the safety case submitted under GSMR would be expected to take five days.

A small gas transporter, who has previously conveyed gas at low pressure only, wishes to move to a two-tier pressure system. This requires a material revision to their accepted GSMR safety case. Assessment of this revision would be expected to take two days.

A large gas transporter operating extensive transmission and distribution systems wishes to make a change to the way it odorises gas. This requires a material revision to their accepted GSMR safety case. Although the revision would be very small in terms of content, perhaps only a few lines of text, it would have to be justified by a detailed hazard and risk assessment document. The assessment process would be expected to take 60 days.

A large gas transporter plans to carry out a significant re-organisation of its structure and management arrangements. This requires a material revision to their accepted GSMR safety case. The assessment process would be expected to take 30 days.

A large gas transporter proposes a restructuring which involves selling major parts of its distribution network business. This would require a material revision to the gas transporter's existing safety case and submission of new safety cases for the new operators. This would require a detailed assessment looking at compliance with all requirements within GSMR. The assessment process for each type of safety case would be expected to take 70 days.

Inspection and Assessment

The NEC carries out a test of its arrangements for preventing a network supply emergency. The test is done with inspectors observing at several sites to verify compliance with the procedures and arrangements set out in the NEC's accepted GSMR safety case. The inspection time would be expected to amount to three days. However, this period would also include time spent on checking gas transporters' compliance with their safety cases and would therefore not all be cost recoverable to the NEC.

A gas conveyor who is a licensed gas transporter, installs piped distribution systems operating at low pressure only. Typically, these systems supply gas to new housing estates and there are several hundred of them scattered around the country. An inspection is made to verify compliance with the procedures and arrangements described in their accepted GSMR safety case. Pre-planning, site visits and post-visit action would be expected to amount to seven days in total.

A large gas transporter operating extensive transmission and distribution systems and employing several thousand people is subject to a rolling three years inspection strategy which, among other things, is intended to verify compliance with the accepted GSMR safety case. Inspection work will be carried out by regulatory and technical specialists and will, in each year, address selected topics, for example, network analysis, management of contractors, dealing with supply emergencies. Some of this work may be done as part of wider, audit activity. The amount of work will vary from year to year but is likely to be of the order of six days.

An inspector is reviewing a notification under the Pipelines Safety Regulations 1996 [PSR], regulation 20, concerning a proposal to construct a new major accident hazard pipeline which will be part of a network for which a GSMR safety case has been accepted. Any work involving assessment of the proposal, which is likely to include discussions with the operator or the person who has commissioned the design and construction of the pipeline if they are different, would be cost recoverable. This may typically take six days but the actual time spent will vary considerably depending on the notification being assessed.

An inspector reviews an operator's emergency procedures (required under PSR regulation 24) concerning a major accident hazard pipeline forming part of a network. This may include overseeing an emergency exercise. In preparation, a site visit and reporting, this would be expected to take two days.

An inspector visits a gas compressor site which forms part of a GSMR network. The inspection involves assessing the measures for minimising the risks from a fire or explosion from a gas leak on the plant. Specifically it includes checking compliance with the Dangerous Substances and Explosive Atmosphere Regulations 2002. Costs would be recoverable for this work and the time taken in preparing for the visit, on-site activities and reporting may take three days.

An audit of an operator’s permit-to-work system for controlling risks from a gas network is undertaken. Typically this would involve two inspectors, include a review of documentation, interviews with management and staff and a report with a follow-up visit. For a complex network, this could result in ten days of cost recoverable work.

Investigation

An employee is carrying out a non-routine operation on a pipeline forming part of a GSMR network. There is a failure in the system of work which results in a release of gas, exposing the employee to a risk of injury. An inspector investigates the incident, looking at operating procedures, standards of supervision, training and competence. The time spent on the investigation would be subject to cost recovery. The costs would vary significantly depending on the extent of the failings and action taken by the Inspector.

A major investigation is undertaken into a release of gas from the network and subsequent explosion which resulted in an injury to a member of the public. The cost of HSE's investigation would be recoverable subject to the exclusions described earlier in this guide.

A member of the public makes a complaint about a persistent smell of gas from a network. The complaint is investigated by an Inspector. This may be done through a phone contact with the operator, requesting an investigation and report back. Alternatively, a site visit and interviews may take place. Where there was a risk of injury from gas, this work would be cost recoverable. The costs would vary dependent on the extent of the investigation.

An employee's representative makes a complaint relating to issues which affect the way gas is conveyed or used. An example would be shortcomings in the procedures for responding to a gas incident. A proportion or all of the time investigating the complaint (dependent on the findings) would be cost recoverable.

Non-cost recoverable activities

A contractor is laying new gas pipes. There are deficiencies in the way the trench is supported which puts employees at risk from a trench collapse. This risk is not related to a risk from the gas and therefore any work done in inspecting or investigating the situation is not cost recoverable.

An operator of a point-to-point pipeline conveying gas from the national transmission system to a power station has been granted an exemption from the requirement to produce a safety case. Any time spent by an inspector considering aspects of the way the gas is conveyed or used in relation to that pipeline would not be cost recoverable.

An inspector is looking at the measures to minimise the risks to employees of sustaining an injury from hand arm vibration from the use of percussive tools whilst excavating gas mains. This is a serious occupational health risk but is not concerned with the risk to the employees from gas and is therefore not cost recoverable.

Time spent ensuring compliance with the Control of Substances Hazardous to Health Regulations 1999 in so far as they relate to the risks from substances to which employees may be exposed to during, for example, ground works, would not be cost recoverable.

Time spent inspecting employers compliance with the Manual Handling Operations Regulations 1992, for example concerning the risk of injury to employees from handling gas pipes, would not be cost recoverable.

An investigation is conducted into a release of gas from downstream of the emergency control valve and a subsequent explosion. The investigation does not relate to operations on the network and hence work on this investigation would not be cost recoverable function which relates to the enforcement of any of the relevant statutory provisions.

Updated 2010-07-07