# 2026 Gas Distribution IA Question Set

- **operation:** document
- **citation:** PHMSA GD.2026.01
- **title:** 2026 Gas Distribution IA Question Set
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2025-12-31
- **effective on:** 2025-12-31
- **summary:** PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026 1. Immediate Reporting: Incidents Is there a process to immediately report incidents to the National Response Center? (RPT.RR.IMMEDREPORT.P) 191.5(b) (191.7(a);191.7(d))
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- **app url:** https://regulus.evalyn.ai/document/phmsa-2026-gas-distribution-ia-question-set
- **source url:** https://www.phmsa.dot.gov/forms/phmsa-gas-distribution-ia-question-set-pdf
**body:**

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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Reporting
1. Immediate Reporting: Incidents Is there a process to immediately report incidents to the National Response
Center? (RPT.RR.IMMEDREPORT.P) 191.5(b) (191.7(a);191.7(d))
2. Incident Reports Does the process require preparation and filing of an incident report as soon as practicable but no later
than 30 days after discovery of a reportable incident? (RPT.RR.INCIDENTREPORT.P) 191.9(a)
3. Supplemental Incident Reports Does the process require preparation and filing of supplemental incident reports?
(RPT.RR.INCIDENTREPORTSUPP.P) 191.9(b)
4. National Registry of Pipeline and LNG Operators (OPID) Does the process require the obtaining, and
appropriate control, of Operator Identification Numbers (OPIDs), including changes in entity, acquisition/divestiture, and
construction/update/uprate? (RPT.RR.OPID.P) 191.22(a) (191.22(c);191.22(d))
5. Safety Related Condition Reports Do the procedures require reporting of safety-related conditions?
(RPT.RR.SRCR.P) 192.605(a) (191.23(a);191.23(b);191.25(a);191.25(c))
6. Safety Related Conditions Does the process include instructions enabling personnel who perform operation and
maintenance activities to recognize conditions that may potentially be safety-related conditions? (MO.GO.SRC.P) 192.605(a)
(192.605(d);191.23(a))
Procedures - Customer and EFV Installation Notification
1. Customer Notification Is a customer notification process in place that satisfies the requirements of 192.16?
(MO.GO.CUSTNOTIFY.P) 192.13(c) (192.16(a);192.16(b);192.16(c);192.16(d))
2. EFV Installation Is there an adequate excess flow valve (EFV) installation and performance program in place?
(MO.GO.EFVINSTALL.P) 192.383(b) (192.381(a);192.381(b);192.381(c);192.381(d);192.381(e);192.383(a);192.383(c))
GD.2026.01 (Intrastate) Page 1 of 91

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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Normal Operating And Maintenance
1. Normal Maintenance and Operations Does the process include a requirement to review the manual at intervals
not exceeding 15 months, but at least once each calendar year? (MO.GO.OMANNUALREVIEW.P) 192.605(a)
2. Normal Operations and Maintenance Procedures - History Does the process include requirements for
making construction records, maps and operating history available to appropriate operating personnel? (MO.GO.OMHISTORY.P)
192.605(a) (192.605(b)(3))
3. Normal Operations and Maintenance Procedures Does the process include requirements for starting up and
shutting down any part of the pipeline in a manner to assure operation with the MAOP limits, plus the build-up allowed for
operation of pressure-limiting and control devices? (MO.GOMAOP.MAOPLIMIT.P) 192.605(a) (192.605(b)(5))
4. Normal Operations and Maintenance Procedures - Review Does the process include requirements for
periodically reviewing the work done by operator personnel to determine the effectiveness, and adequacy of the processes used in
normal operations and maintenance and modifying the processes when deficiencies are found? (MO.GO.OMEFFECTREVIEW.P)
192.605(a) (192.605(b)(8))
5. Safety While Making Repairs Does the process ensure that repairs are made in a safe manner and are made so as
to prevent damage to persons and property? (AR.RMP.SAFETY.P) 192.605(b)(9) (192.713(b))
6. Holders Does the process include systematic and routine testing and inspection of pipe-type or bottle-type holders?
(MO.GM.HOLDER.P) 192.605(a) (192.605(b)(10))
7. Gas Odor Response Does the process require prompt response to the report of a gas odor inside or near a building?
(MO.GO.ODDOR.P) 192.605(a) (192.605(b)(11))
8. Business District Definition Do the procedures define a “Business District”? (MO.RW.BUSINESSDIST.P)
192.723(b)(1) (192.721(b)(1);192.723(a);192.613)
9. Qualification of Personnel Making Joints in Plastic Pipelines Does the process require personnel making
joints in plastic pipelines be qualified? (TQ.QUOMCONST.PLASTIC.P) 192.285(a) (192.285(d);192.805(b);192.285(c))
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
10. Plastic Leak Repair - Mechanical Clamps Does the operator’s process ensure that mechanical leak clamps are
not used as a permanent repair method for plastic pipe? (AR.RCOM.PLASTICLEAKCLAMP.P) 192.720
11. Plastic Pipe - Storage and Handling of Pipe and Components Does the operator have a written
procedure for the storage and handling of plastic pipe and associated components? (DC.PLASTIC.PLASTICHANDLING.P) 192.69
(192.59;192.63(e);192.321(g))
12. Container Owner Notification Do the procedures require notification, in writing, to the container owner and user
when noncompliance with Section 5.2, Containers, or Section 5.9, Container Appurtenances, or a defect is found per Section
7.2.2.7 so that the container will not be filled? (LPG.NFPA58-MOGM.NOTIFY.P) 192.7(i)(2) (192.11;NFPA 58 (2020) 7.2.2.2)
13. General Operations & Emergency Response Training Do procedures require persons whose duties fall
within NFPA 58 requirements to have training consistent with the scope of their job activities, including proper handling and
emergency response procedures? (LPG.NFPA58-TQ.EMERGPROCED.P) 192.7(i)(2) (192.11;NFPA 58 (2020) 4.4.1)
14. Transfer Operations Training - Refresher Do procedures require personnel involved in transfer duties are
given refresher training at least every three years? (LPG.NFPA58-TQ.REFRESHER.P) 192.7(i)(2) (192.11;NFPA 58 (2020) 4.4.3)
15. Transfer Operations Training Does the procedure require transfer operations to be conducted only by individuals
familiar with the properties of the material and instructed in transfer and emergency procedures? (LPG.NFPA58-
TQ.TRANSFEROPS.P) 192.7(i)(2) (192.11;NFPA 58 (2020) 7.2.2.1)
16. Transfer Operations Training Do procedures require persons whose primary duties, include transferring liquid LP-
Gas into or out of stationary containers, to complete training per the requirements of 4.4.2? (LPG.NFPA58-TQ.TRANSFERDUTY.P)
192.7(i)(2) (192.11;NFPA 58 (2020) 4.4.2)
17. Transfer Operations Training - Refresher Do procedures require initial and subsequent personnel refresher
training to be documented? (LPG.NFPA58-TQ.REFRESHERDOC.P) 192.7(i)(2) (192.11;NFPA 58 (2020) 4.4.4)
18. Facility Components Enclosures Do procedures require that major facility components be enclosed by a fence,
wall, or natural barrier that will minimize pocketing of escaping gas, interference with fire fighting efforts, and blocking of
personnel exits? (LPG.NFPA59-MOGM.FACILENCLOSE.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 13.9.2)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
19. Emergency Procedures Manual Do procedures require a comprehensive emergency manual, that is updated
annually, and is readily accessible? (LPG.NFPA59-MOGO.EMERGMANUAL.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 13.1.3)
20. Personnel Safety - Protective Clothing Do procedures require that require that personnel involved in
emergency activities have protective clothing and equipment, including helmets, face shields, gloves, and boots, and that they are
trained in the proper use of the equipment? (LPG.NFPA59-MOGO.PROTCLOTHING.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 13.8.4)
21. Emergency Procedures Manual - Emergency Conditions Does the emergency procedures manual include
the potential emergency conditions that can develop whether or not a fire has occurred? (LPG.NFPA59-MOGO.EMERGCOND.P)
192.7(i)(3) (192.11;NFPA 59 (2018) 13.1.3;NFPA 58 (2020) 6.29.2.1)
22. Filling Densities Does the procedure require that filling density restrictions comply with NFPA 59 section 5.7?
(LPG.NFPA59-MOGO.FILLING.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 5.7)
23. Personnel Safety - Action During Vapor Detection Do procedures require necessary actions to be taken if
flammable concentrations of liquid or vapor are detected by fixed detectors, portable detectors, operating malfunctions and human
senses? (LPG.NFPA59-MOGO.FIREPROTDET.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.1.2)
24. Personnel Safety - Gas Detectors Do procedures require portable flammable gas detectors to be available?
(LPG.NFPA59-MOGO.GASDETECTORS.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 13.8.6)
25. Portable Fire-Extinguishing Equipment Do procedures require portable or wheeled fire extinguishers of the dry
chemical type at least 18 lbs with a B:C rating? (LPG.NFPA59-MOGO.FIREEXTING.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 13.5.1)
26. Maintenance of Fire Protection Equipment (197) Do procedures (maintenance manuals) require that a
maintenance program for all fire protection equipment be prepared and implemented? (LPG.NFPA59-MOGO.FIREEQUIPMTCE.P)
192.7(i)(3) (192.11;NFPA 59 (2018) 13.7)
27. Maintenance of Fire Protection Equipment (198) Do procedures (maintenance manuals) require that fire
control equipment maintenance be performed to minimize the amount of equipment out of service? (LPG.NFPA59-
MOGO.FIREEQUIPOOS.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 12.6)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
28. Personnel Safety - LPG Contact Do procedures require that all personnel be advised of the danger of frostbite
from LPG contact and that protective clothing and equipment be available? (LPG.NFPA59-MOGO.HANDLINGLPG.P) 192.7(i)(3)
(192.11;NFPA 59 (2018) 13.8.3)
29. Ignition Source Control Does the procedure require the operator to minimize risk associated with accidental ignition
of flammable LP-Gases due to a release of liquid or vapor? (LPG.NFPA59-MOGO.IGNITION.P) 192.7(i)(3) (192.11;NFPA 59 (2018)
4.5.1.1)
30. Gas-Air Mixers - Safety Interlocks Do procedures require that gas-air mixers be provided with safety interlocks
to prevent the introduction of either undiluted air or vapor into the gas distribution lines? (LPG.NFPA59-MOGO.INTERLOCK.P)
192.7(i)(3) (192.11;NFPA 59 (2018) 9.4.2(2))
31. Purging Prior to Maintenance Do procedures require adequate purging prior to performing maintenance activities?
(LPG.NFPA59-MOGO.PURGING.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.2.3;NFPA 59 (2018) 12.9)
32. Inspection of Containers - OOS For reinstalled nonrefrigerated containers that have been out of service for more
than one year, do procedures require inspections be performed in accordance with the ANSI/NB23 National Board Inspection
Code? (LPG.NFPA59-MOGO.OOSINSPECTION.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 5.6;ANSI/NB23 National Board Inspection
Code)
33. Leak Testing of All Components Do procedures require that all components be leak tested after assembly at
normal operating pressure? (LPG.NFPA59-MOGO.LEAKTEST.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 7.1.9)
34. Conflict Between Part 192 and NFPA58 and 59 Do the procedures acknowledge that in the event of a
conflict between Part 192 and ANSI/NFPA 58 and 59, ANSI/NFPA 58 and 59 prevail? (LPG.NFPA59-MOGO.CONFLICT.P) 192.11(c)
35. Auxiliary Power Sources Do procedures (maintenance manuals) require that each auxiliary power source be tested
monthly to verify its capability? (LPG.NFPA59-MOGO.AUXPOWER.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 12.8)
36. Purging of Equipment - General Do procedures include purging and inerting of equipment? (LPG.NFPA59-
MOGO.PURGINGGEN.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.2.3)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
37. Purging Prior to Maintenance Do maintenance manuals require that equipment containing flammable or
hazardous materials must be purged prior to performing maintenance activities? (LPG.NFPA59-MOGO.PURGINGMTCE.P)
192.7(i)(3) (192.11;NFPA 59 (2018) 12.9)
38. Gas-Air Mixers - Gas Mixture Quality Do procedures require that gas-air mixers produce a mixture of natural
gas, air, and LP-Gas vapor that is interchangeable with natural gas? (LPG.NFPA59-MOGO.GASQUALITY.P) 192.7(i)(3)
(192.11;NFPA 59 (2018) 9.4.2(1))
39. Operating Log Sheets / Records Do procedures require operating log sheets required under section 11.4.1 to be
retained for at least five years? (LPG.NFPA59-MOGO.RECORDS.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.3.2)
40. Equipment Maintenance Records Do procedures require that records are kept of all maintenance log sheets for
process equipment? (LPG.NFPA59-MOGO.RECORDSLOG.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 12.10)
41. Other Sources of Ignition - Smoking Does the procedure restrict smoking to properly posted areas?
(LPG.NFPA59-MOGO.SMOKING.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 4.5.3.1)
42. Operations Procedures Do the procedures cover facility startup, operation, and shutdown? (LPG.NFPA59-
MOGO.OPSPROCED.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.1.2)
43. Other Sources of Ignition - Stray Currents Do procedures require protective measures be taken to prevent
ignition from stray currents? (LPG.NFPA59-MOGO.STRAYCURRENT.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 4.5.5)
44. Facility & Components Corrosion Protection Do procedures require nonrefrigerated underground and
aboveground facilities/components to be corrosion protected with the proper coating? (LPG.NFPA59-MOGO.CORRPROTCOMP.P)
192.7(i)(3) (192.11;NFPA 59 (2018) 5.5.2.9;NFPA 59 (2018) 5.5.1.5;NFPA 58 (2020) 6.19.1)
45. Container Corrosion Protection Do procedures require nonrefrigerated underground containers to be protected
against corrosion? (LPG.NFPA59-MOGO.CORRPROTCONT.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 5.5.2.9)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
46. Welding Limitations Do procedures require that welding on nonrefrigerated underground containers be limited to
attachments to non-pressure parts such as saddles, wear plates, or brackets installed by the container manufacturer?
(LPG.NFPA59-MOGO.WELDINGLIMITS.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 5.5.3)
47. Welding Procedural Requirements Do procedures require welding, cutting, and hot work to be conducted in
accordance with the provisions of NFPA 51B? (LPG.NFPA59-MOGO.WELDINGPROCED.P) 192.7(i)(3) (192.11;NFPA 59 (2018)
4.5.3.2)
48. Truck Wheels Blocking During Loading/Unloading Do procedures require truck wheels to be blocked
during loading or unloading? (LPG.NFPA59-MOGO.WHEELS.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.3.4.1)
49. Electrical Equipment & Wiring Requirements Do procedures require electrical equipment and wiring to meet
NFPA 70 for ordinary locations? (LPG.NFPA59-MOGO.WIRING.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 4.7.1;NFPA 59 (2018)
4.5.2.2)
50. Personnel Training - Handling LPG Do the procedures require operating personnel to be trained (at least
annually) in the properties and safe handling of liquified petroleum gases and in emergency procedures? (LPG.NFPA59-
TQ.HANDLINGLPG.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 13.1.4;NFPA 59 (2018) 4.1)
51. Transfer Operations Training - Competency Do the procedures require that at least one competent trained
person be near the transfer operation during the transfer? (LPG.NFPA59-TRANSFER.COMPETENT.P) 192.7(i)(3) (192.11;NFPA 59
(2018) 11.3.1.2)
52. Transfer Operations Procedures Do the procedures cover all transfer operations and do they cover emergency as
well as normal operating procedures? (LPG.NFPA59-TRANSFER.TRANSFEROPS.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 11.3.1.3)
53. Testing Relief Devices Do procedures require relief devices to be tested every five years? (LPG.NFPA59-
MOGM.RELIEFDEVICES.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 10.1.4)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Change In Class Location
1. Change in Class Location - Required Study Does the process include a requirement that the operator conduct a
study whenever an increase in population density indicates a change in the class location of a pipeline segment operating at a
hoop stress that is more than 40% SMYS? (MO.GOCLASS.CLASSLOCATESTUDY.P) 192.605(b)(1)
(192.609(a);192.609(b);192.609(c);192.609(d);192.609(e);192.609(f))
2. Change in Class Location Confirmation or Revision of MAOP Does the process include a requirement that
the MAOP of a pipeline segment be confirmed or revised within 24 months whenever the hoop stress corresponding to the
established MAOP is determined not to be commensurate with the existing class location? (MO.GOCLASS.CLASSLOCATEREV.P)
192.605(b)(1) (192.611(a);192.611(b);192.611(c);192.611(d))
Procedures - Continuing Surveillance
1. Continuing Surveillance Are there processes for performing continuing surveillance of pipeline facilities, and also for
reconditioning, phasing out, or reducing the MAOP in a pipeline segment that is determined to be in unsatisfactory condition but on
which no immediate hazard exists? (MO.GO.CONTSURVEILLANCE.P) 192.605(e) (192.613(a);192.613(b);192.703(b);192.703(c))
Procedures - Damage Prevention Program
1. Damage Prevention Program Is a damage prevention program approved and in place? (PD.DP.PDPROGRAM.P)
192.614(a)
2. Participation in Qualified One Call Systems Does the process require participation in qualified one-call
systems? (PD.DP.ONECALL.P) 192.614(b)
3. Construction Marking Does the process require marking proposed excavation sites to the Common Ground Alliance's
(CGA) Best Practices or the use of more stringent and accurate requirements? (PD.DP.EXCAVATEMARK.P) 192.614(c)(5)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
4. Documented Damage Prevention Program - TPD Does the process specify how reports of Third-Party Activity
and names of associated contractors or excavators are input back into the mail-outs and communications with excavators along
the system? (PD.DP.TPD.P) 192.614(c)(1)
5. Documented Damage Prevention Program - TPD/One Call Does the process specify how reports of TPD
are checked against One-Call tickets? (PD.DP.TPDONECALL.P) 192.614(c)(3)
Procedures - Emergency
1. Receiving Notices Does the emergency plan include procedures for receiving, identifying, and classifying notices of
events which need immediate response? (EP.ERG.NOTICES.P) 192.615(a)(1)
2. Emergency Response Communication Does the emergency plan include procedures for establishing and
maintaining adequate means of communication with appropriate fire, police, and other public officials? (EP.ERG.COMMSYS.P)
192.615(a) (192.615(a)(2))
3. Emergency Response Does the emergency plan include procedures for making a prompt and effective response to a
notice of each type of emergency, including gas detected inside or near a building, a fire or explosion near or directly involving a
pipeline facility, operational failure (including Cyber-attacks), or a natural disaster? (EP.ERG.RESPONSE.P) 192.615(a)
(192.615(a)(3);192.615(a)(11);192.615(b)(1))
4. Emergency Response Does the process include procedures for ensuring the availability of personnel, equipment, tools,
and materials as needed at the scene of an emergency? (EP.ERG.READINESS.P) 192.615(a) (192.615(a)(4))
5. Emergency Response - Actions Does the emergency plan include procedures for taking actions directed toward
protecting people first and then property? (EP.ERG.PUBLICPRIORITY.P) 192.615(a) (192.615(a)(5))
6. Emergency Response Does the emergency plan include procedures for the emergency shutdown or pressure reduction
in any section of pipeline system necessary to minimize hazards to life or property? (EP.ERG.PRESSREDUCESD.P) 192.615(a)
(192.615(a)(6))
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
7. Emergency Response - Hazards Does the emergency plan include procedures for making safe any actual or
potential hazard to life or property? (EP.ERG.PUBLICHAZ.P) 192.605(a) (192.615(a)(7))
8. Public Official Notification Does the emergency plan include procedures for notifying appropriate public officials of
gas pipeline emergencies and coordinating with them both planned responses and actual responses during an emergency?
(EP.ERG.AUTHORITIES.P) 192.615(a) (192.615(a)(8))
9. Emergency Response - Designated Persons Notify 911 Does the emergency plan define the operator’s
designated person(s) (e.g., controller or other personnel) responsible to directly notify 911 or the phone number of appropriate
local emergency officials to report emergencies and possible pipeline ruptures to first responder agencies/authorities?
(EP.ERG.NOTIFY911.P) 192.615(a) (192.615(a)(8);NTSB P-11-9)
10. Service Outage Restoration Does the emergency plan include procedures for safely restoring any service outage?
(EP.ERG.OUTAGERESTORE.P) 192.615(a) (192.615(a)(9))
11. Incident Investigation Actions Does the process include procedures for beginning action under 192.617, if
applicable, as soon after the end of the emergency as possible? (EP.ERG.INCIDENTACTIONS.P) 192.615(a) (192.615(a)(10))
12. Emergency Response Training Does the process include training of the appropriate operating personnel to assure
they are knowledgeable of the emergency procedures and verifying that the training is effective? (EP.ERG.TRAINING.P)
192.615(b)(2)
13. Emergency Response Performance Does the process include detailed steps for reviewing employee activities to
determine whether the procedures were effectively followed in each emergency? (EP.ERG.POSTEVNTREVIEW.P) 192.615(b)(3)
14. Liaison with Public Officials Does the process include steps for establishing and maintaining liaison with
appropriate fire, police, other public officials, and 911 emergency call centers? (EP.ERG.LIAISON.P) 192.615(c)
(192.615(c)(1);192.615(c)(2);192.615(c)(3);192.615(c)(4);192.616(c);ADB-2005-03)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Public Awareness Program
1. Master Meter and Petroleum Gas Systems Does the public awareness program for a master meter or
petroleum gas system meet the requirements of Part 192? (PD.PA.MSTRMETER.P) 192.616(j) (192.616(h))
Note: this question is presented in multiple places so you will see multiple instances of it on this report.
Procedures - Failure Investigation
1. Incident Investigation Does the process include procedures for analyzing accidents and failures, including the
selection of samples of the failed facility or equipment for laboratory examination, where appropriate, for the purpose of
determining the causes of the failure and minimizing the possibility of recurrence? (EP.ERG.INCIDENTANALYSIS.P) 192.617
Procedures - MAOP
1. Maximum Allowable Operating Pressure Determination Does the process include requirements for
determining the maximum allowable operating pressure for a pipeline segment in accordance with 192.619?
(MO.GOMAOP.MAOPDETERMINE.P) 192.605(b)(1) (192.619(a);192.619(b);192.621(a);192.621(b);192.623(a);192.623(b))
2. Design of Plastic Pipe (192.121) Does the process require the design pressure for plastic pipe to be determined in
accordance with §192.121? (DC.PLASTIC.DESIGNPRESSPLASTIC.P) 192.121
3. Plastic Pipe Specifications Does the operator's specifications require plastic pipe to meet the requirements of
§192.53, §192.59, and other applicable requirements of this sub-part? (DC.PLASTIC.PLASTICSPECS.P) 192.53 (192.59)
4. Design Pressure of Plastic Components / Fittings Does the process require plastic components and fittings
are able to withstand operating pressures and other anticipated loads in accordance with a listed specification?
(DC.PLASTIC.PLASTICFITTING.P) 192.143(c) (192.149(c))
5. Marking of Materials Does the operator's specifications require pipe, valves, and fittings to be marked according to the
requirements of §192.63? (DC.MA.MARKING.P) 192.63
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Pressure Test
1. Test Acceptance Criteria and Procedures Were test acceptance criteria and procedures/processes sufficient to
assure the basis for an acceptable pressure test? (AR.PTI.PRESSTESTACCEP.P) 192.503(a)
(192.503(b);192.503(c);192.503(d);192.503(e);192.505(a);192.505(b);192.505(c);192.505(d);192.507(a);192.507(b);192.507(
c);192.513(a);192.513(b);192.513(c);192.513(d))
2. Test Requirements for Plastic Pipe Does the process require that, as applicable to the project, sections of a plastic
pipeline must be tested in accordance with the requirements of §192.513? (DC.PLASTIC.PRESSTESTPLASTIC.P) 192.513(a)
(192.143(a);192.121(a);192.513(b);192.513(c);192.513(d);192.143(b);192.143(c);192.121(b);192.121(c);192.121(d);192.121(
e);192.121(f))
Procedures - Odorization Of Gas
1. Odorization of Gas Does the process ensure appropriate odorant levels are contained in its combustible gases in
accordance with 192.625? (MO.GOODOR.ODORIZE.P) 192.605(b)(1)
(192.625(a);192.625(b);192.625(c);192.625(d);192.625(e);192.625(f))
2. LP-Gas Odorization Do procedures require a bill of lading review and performing sniff tests to ensure adequate
odorization? (LPG.NFPA58-MOGOODOR.SNIFFTEST.P) 192.7(i)(2) (192.11;NFPA 58 (2020) 4.2.1;NFPA 58 (2020) 4.2.3;NFPA 59
(2018) 4.2)
3. LP-Gas Odorization Do procedures require LPG to be odorized so that it is detectable down to a concentration of one-
fifth the lower limit of flammability? (Bill of Lading) (LPG.NFPA58-MOGOODOR.ODORIZE.P) 192.7(i)(2) (192.11;NFPA 58 (2020)
4.2)
4. Odorizing Gases Do procedures require LPG to be odorized so that it is detectable down to a concentration of one-fifth
the lower limit of flammability? (Bill of Lading) (LPG.NFPA59-MOGOODOR.ODORIZE.P) 192.7(i)(3) (192.11;NFPA 59 (2018) 4.2)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Tapping Pipelines Under Pressure
1. Tapping Pipelines Under Pressure Is the process adequate for tapping pipelines under pressure?
(AR.RMP.HOTTAP.P) 192.605(b)(1) (192.627)
2. Qualification of Personnel Tapping Pipelines under Pressure Does the process require taps on a pipeline
under pressure (hot taps) to be performed by qualified personnel? (TQ.QU.HOTTAPQUAL.P) 192.627 (192.805(b))
Procedures - Pipeline Purging
1. Pipeline Purging Does the process include requirements for purging of pipelines in accordance with 192.629?
(MO.GO.PURGE.P) 192.605(b)(1) (192.629(a);192.629(b))
Procedures - Line Marker
1. ROW Markers Requirements Does the process adequately cover the requirements for placement of ROW markers?
(MO.RW.ROWMARKER.P) 192.707(a) (192.707(b);192.707(d))
Procedures - Distribution System Patrolling & Leakage Survey
1. Distribution Patrolling Does the process require distribution system patrolling to be conducted?
(MO.RW.DISTPATROL.P) 192.721(a) (192.721(b))
2. Distribution Leakage Surveys Does the process require distribution system leakage surveys to be conducted?
(MO.RW.DISTLEAKAGE.P) 192.723(a) (192.723(b))
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Transmission System Patrolling & Leakage Survey
1. Transmission Patrolling Requirements Does the process adequately cover the requirements for transmission
line patrolling the ROW and conditions reported? (MO.RW.TRANSPATROL.P) 192.705(a) (192.705(b);192.705(c))
2. Transmission Leakage Surveys Does the process require transmission leakage surveys to be conducted?
(MO.RW.TRANSLEAKAGE.P) 192.706 (192.706(a);192.706(b))
Procedures - Test Requirements For Reinstating Service Lines
1. Test Reinstated Service Lines Is the process adequate for the testing of disconnected service lines?
(AR.RMP.TESTREINSTATE.P) 192.605(b) (192.725(a);192.725(b))
Procedures - Abandonment Or Deactivation Of Facilities
1. Abandonment or Deactivation of Pipe and Facilities Does the process include adequate requirements for
the abandonment and deactivation of pipelines and facilities? (MO.GM.ABANDONPIPE.P) 192.605(b)(1)
(192.727(a);192.727(b);192.727(c);192.727(d);192.727(e);192.727(f);192.727(g))
Procedures - Pressure Limiting And Regulating Station
1. Pressure Limiting and Regulating Stations Inspection and Testing Does the process include
procedures for inspecting and testing each pressure limiting station, relief device, and pressure regulating station and their
equipment? (MO.GMOPP.PRESSREGTEST.P) 192.605(b)(1) (192.739(a);192.739(b))
2. Pressure Telemetering or Recording Gauges Does the process require telemetering or recording gauges be
utilized as required for distribution systems? (MO.GMOPP.PRESSREGMETER.P) 192.605(b)(1) (192.741(a);192.741(b);192.741(c))
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
3. Pressure Limiting and Regulating Stations Capacity of Relief Devices Does the process include
procedures for ensuring that the capacity of each pressure relief device at pressure limiting stations and pressure regulating
stations is sufficient? (MO.GMOPP.PRESSREGCAP.P) 192.605(b)(1) (192.743(a);192.743(b);192.743(c))
4. Protection against Accidental Overpressuring Does the process require the pipeline have pressure relieving
or pressure limiting devices that are required of 192.195(a), and that they meet the requirements of 192.199 and 192.201?
(DC.DPCOPP.OVERPRESSURE.P) 192.303 (192.143(b);192.195(a);192.199;192.201(a);192.201(b);192.201(c);192.143(a))
Procedures - Valve And Vault Maintenance
1. Valve Maintenance Distribution Lines Does the process include procedures for inspecting and partially operating
each distribution system valve that might be required in an emergency at intervals not exceeding 15 months, but at least once
each calendar year and for taking prompt remedial action to correct any valve found inoperable? (MO.GM.DISTVALVEINSPECT.P)
192.605(b)(1) (192.747(a);192.747(b))
Procedures - Vault Inspection
1. Vault Inspection What are process requirements for inspecting vaults having a volumetric internal content ≥200 cubic
feet (5.66 cubic meters) that house pressure regulating/limiting equipment? (FS.FG.VAULTINSPECT.P) 192.605(b)(1)
(192.749(a);192.749(b);192.749(c);192.749(d))
Procedures - Prevention Of Accidental Ignition
1. Prevention of Accidental Ignition Are there processes for minimizing the danger of accidental ignition where gas
constitutes a hazard of fire or explosion? (MO.GM.IGNITION.P) 192.605(b)(1) (192.751(a);192.751(b);192.751(c))
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
Procedures - Caulked Bell And Spigot Joints
1. Bell and Spigot Joints Does the process require that caulked bell and spigot joints be correctly sealed?
(MO.GM.BELLSPIGOTJOINT.P) 192.753(a) (192.753(b))
Procedures - Protecting Cast-Iron Pipeline
1. Protecting Cast-Iron Pipeline Does the process require adequate protection for segments of a buried cast-iron
pipeline for which support has been disturbed? (MO.GM.CASTIRONPROTECT.P) 192.755(a) (192.755(b))
Procedures - Welding And Weld Defect Repair/removal
1. Welding Procedures Does the process require welding to be performed by qualified welders using qualified welding
procedures and are welding procedures and qualifying tests required to be recorded in detail? (DC.WELDPROCEDURE.WELD.P)
192.225(a) (192.225(b))
2. Qualification of Welders Does the process require welders to be qualified in accordance with API Std 1104 (21st
Edition) or the ASME Boiler & Pressure Vessel Code-2007? (TQ.QUOMCONST.WELDER.P) 192.227(a)
(192.225(a);192.225(b);192.328(a);192.328(b))
3. Qualification of Welders for Low Stress Pipe Does the process require welders who perform welding on low
stress pipe on lines that operate at < 20% SMYS to be qualified under Section I of Appendix C to Part 192, and are welders who
perform welding on service line connection to a main required to be qualified under Section II of Appendix C to Part 192?
(TQ.QUOMCONST.WELDERLOWSTRESS.P) 192.227(b) (192.225(a);192.225(b);192.805(b))
4. Limitations on Welders Does the process require certain limitations be placed on welders and welding operators in
accordance with 192.229? (DC.WELDERQUAL.WELDERLIMITNDT.P) 192.303 (192.229(a);192.229(b);192.229(c);192.229(d))
5. Welding Weather Does the process require welding to be protected from weather conditions that would impair the
quality of the completed weld? (DC.WELDPROCEDURE.WELDWEATHER.P) 192.303 (192.231)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
6. Miter joints Does the process prohibit the use of certain miter joints as required by 192.233?
(DC.WELDPROCEDURE.MITERJOINT.P) 192.303 (192.233(a);192.233(b);192.233(c))
7. Preparation for Welding Does the process require certain preparations for welding, in accordance with 192.235?
(DC.WELDPROCEDURE.WELDPREP.P) 192.303 (192.235)
8. Inspection and Test of Welds Does the process require visual inspections of welds to be conducted by qualified
inspectors? (DC.WELDINSP.WELDVISUALQUAL.P) 192.303 (192.241(a);192.241(b);192.241(c))
9. Repair or Removal of Weld Defects Does the process require welds that are unacceptable to be removed and/or
repaired as specified by 192.245? (DC.WELDINSP.WELDREPAIR.P) 192.303 (192.245(a);192.245(b);192.245(c))
Procedures - Nondestructive Testing
1. Nondestructive Test and Interpretation Procedures Is there a process for welds nondestructive testing and
interpretation in accordance with 192.243? (DC.WELDINSP.WELDNDT.P) 192.243(a)
(192.243(b);192.243(c);192.243(d);192.243(e))
Procedures - Joining Of Pipeline Materials
1. Underground Clearance Does the process require pipe to be installed with clearances specified in 192.325 and (if
plastic) installed as to prevent heat damage to the pipe? (DC.CO.CLEARANCE.P) 192.303 (192.325(b);192.325(c))
2. Plastic Pipe Joints Does the process require plastic pipe joints to be designed and installed in accordance with 192.281?
(DC.PLASTIC.PLASTICJOINT.P) 192.273(b) (192.281(a);192.281(b);192.281(c);192.281(d);192.281(e);192.303)
3. Joining of Materials Other than by Welding Does the process require that pipeline joints (to be made other
than by welding) be designed and installed in accordance with 192.273? (DC.CO.NONWELDJOINT.P) 192.303 (192.273)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
4. Plastic Pipe - Qualifying Joining Procedures Does the process require plastic pipe joining procedures to be
qualified in accordance with §192.283, prior to making plastic pipe joints? (DC.PLASTIC.PLASTICJOINTPROCEDURE.P) 192.273(b)
(192.283(a);192.283(b);192.283(c))
5. Plastic Pipe - Qualifying Personnel to Make Joints Is a process in place to ensure that personnel making
joints in plastic pipelines are qualified? (DC.PLASTIC.PLASTICJOINTQUAL.P) 192.285(d)
(192.285(a);192.285(b);192.285(c);192.285(e);192.513;192.803;192.805)
6. Qualification of Personnel Inspecting Joints in Plastic Pipelines Is a process in place to assure that
persons who inspect joints in plastic pipes are qualified? (DC.PLASTIC.PLASTICJOINTINSP.P) 192.287 (192.805(h))
7. Qualification of Personnel Inspecting Joints in Plastic Pipelines Does the process require that persons
who inspect joints in plastic pipes be qualified? (TQ.QUOMCONST.PLASTICINSPECT.P) 192.287 (192.805(b))
8. Installation of Plastic Pipe Does the operator’s process require that plastic pipe be installed as required by
§192.321? (DC.PLASTIC.INSTALLPLASTIC.P) 192.303
(192.321(a);192.321(b);192.321(c);192.321(d);192.321(e);192.321(f);192.321(g);192.321(h);192.321(i))
9. Valve Installation in Plastic Pipe Does the operator have a procedural requirement for plastic pipe valves to be
designed with adequate support to resist against excessive torsional or shearing loads when the valve or shutoff is operated, and
from any other secondary stresses that might be exerted through the valve or its enclosure? (DC.PLASTIC.PLASTICVALVE.P)
192.193
10. Plastic Pipe - Bend Radius Does the operator’s process ensure that the bend radius of plastic pipe does not exceed
the minimum bend radius specified by the manufacture for the diameter being installed? (DC.PLASTIC.BENDPLASTIC.P)
192.313(d) (192.605)
11. Trenchless Installation of Plastic Transmission and Main Pipelines For plastic pipe Transmission
and Main pipelines installed by trenchless excavation, does the process include steps that need to be taken to provide sufficient
clearance for installation and maintenance activities from other underground utilities and/or structures at the time of installation?
(DC.PLASTIC.PLASTICTRENCHLESS.P) 192.329(a) (192.303)
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
12. Trenchless Installation of Plastic Service Lines For plastic service lines installed by trenchless excavation,
does the process include steps that need to be taken to provide sufficient clearance for installation and maintenance activities from
other underground utilities and/or structures at the time of installation? (DC.PLASTIC.PLASTICSERVICE.P) 192.376(a) (192.303)
13. Trenchless Installation of Plastic Lines using a Weak Link Does the process require that during
installation of plastic lines and plastic service lines, a “weak link” (as defined by §192.3) is utilized to ensure the pipeline will not
be damaged by any excessive forces during the pulling process? (DC.PLASTIC.PLASTICWEAKLINK.P) 192.329(b)
(192.376(b);192.303)
14. Repair of Plastic Pipe Does the process require imperfections or damage of plastic pipe to be repaired or removed?
(DC.PLASTIC.REPAIRPLASTIC.P) 192.303 (192.311)
15. Maintenance of Equipment Used in Joining of Plastic Pipe by Heat Fusion Does the process
require maintaining equipment used in joining of plastic pipe using heat fusion in accordance with the manufacturer's
recommended practices or with written procedures that have been proven by test and experience to produce acceptable joints?
(MO.GM.EQUIPPLASTICJOINT.P) 192.605(b)(1) (192.756)
Procedures - Corrosion Control
1. New Buried Pipe Coating Does the process require that each buried or submerged pipeline installed after July 31,
1971 be externally coated with a material that is adequate for underground service on a cathodically protected pipeline?
(TD.COAT.NEWPIPE.P) 192.605(b)(2)
(192.455(a);192.455(b);192.455(c);192.455(d);192.461(a);192.461(b);192.463;192.483(a))
2. Corrosion Control Personnel Qualification Does the process require corrosion control procedures to be carried
out by, or under the direction of, qualified personnel? (TQ.QU.CORROSION.P) 192.453 (192.805(b))
3. Conversion to Service - Pipe Coating Does the process require that each buried or submerged pipeline that has
been converted to gas service and was installed after July 31, 1971, be protected against external corrosion with an adequate
coating unless exempted by 192.455(b)? (TD.COAT.CONVERTPIPE.P) 192.605(b)(2)
(192.452(a);192.455(a);192.455(b);192.455(c);192.455(d);192.461(a))
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PHMSA – Gas Distribution (GD.2026.01 Intrastate) IA Question Set - January 2026
4. Employee Qualification Does the process define the qualifications required for personnel that design, install, operate,
and maintain cathodic protection systems? (TD.EQ.EMPQUAL.P) 192.605(b)(2) (192.453)
5. Cathodic Protection post-July 1971 Does the process require that each buried or submerged pipeline installed
after July 31, 1971, be protected against external corrosion with a cathodic protection system within 1 year after completion of
construction, conversion to s
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