{"operation":"document","citation":"PHMSA Guidance, PHMSA and NAPSR Joint Petition to the Gas Piping Technology Committee (GPTC) (2006)","title":"PHMSA and NAPSR Joint Petition to the Gas Piping Technology Committee (GPTC) (2006)","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":null,"effective_on":null,"summary":"PHMSA and NAPSR Joint Petition to the Gas Piping Technology Committee (GPTC) (2006) Document phmsanapsrlettertogptc.pdf (97.39 KB) PHMSA and NAPSR Joint Petition to the Gas Piping Technology Committee (GPTC) (2006) Effective Date: Sunday, May 1, 2005","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-phmsa-and-napsr-joint-petition-gas-piping-technology-committee-gptc-2006-3b72e9b9.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-phmsa-and-napsr-joint-petition-gas-piping-technology-committee-gptc-2006-3b72e9b9.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-phmsa-and-napsr-joint-petition-gas-piping-technology-committee-gptc-2006-3b72e9b9","source_url":"https://www.phmsa.dot.gov/pipeline/gas-distribution-integrity-management/phmsa-and-napsr-joint-petition-gas-piping-technology-committee-gptc-2006","body":"PHMSA and NAPSR Joint Petition to the Gas Piping Technology Committee (GPTC) (2006)\n\nDocument\n\n phmsanapsrlettertogptc.pdf (97.39 KB)\n\n        PHMSA and NAPSR Joint Petition to the Gas Piping Technology Committee (GPTC) (2006)\n\n          Effective Date: Sunday, May 1, 2005\n\n<<<PAGE 1>>>\n\nU.S. Department 400 Seventh St. S.W.\nof Transportation Washington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAdministration\nMr. John Frantz\nManager Gas Engineering\nPECO Energy\n2301 Market Street\nPhiladelphia, PA 19101-0000\nDear Mr. Frantz,\nThe Department of Transportation's Pipeline and Hazardous Materials Safety Administration\n(PHMSA) and the National Association of Pipeline Safety Representatives (NAPSR) requests\nthat the Gas Piping Technology Committee develop guidance that will help assure the\nintegrity of gas distribution pipelines.\nPHMSA promulgated regulations requiring integrity management (IM) programs for\nhazardous liquid pipelines (in 2000) and gas transmission pipelines (in 2003). Operators of\nthese types of pipelines are required to implement programs that require them to identify the\nthreats to their pipelines, analyze the risks they produce, and take actions as needed to\nmitigate these risks. These regulations require that pipeline operators, as part of their IM\nprograms, conduct periodic inspections of the condition of their pipelines to identify and\nremediate conditions that could threaten pipeline integrity.\nDistribution pipelines are not currently subject to IM regulations. Design differences between\ndistribution pipelines and the pipelines now covered by IM regulations preclude use of the\ninspection techniques required by these regulations. At the same time, other elements of the\nIM regulations could be applied to distribution pipelines. The DOT Inspector General, testifying\nbefore Congress in 2004, recommended that IM programs be required of distribution pipeline\noperators. The report of the FY 2005 Conference Committee on Appropriations required DOT\nto report to the Congress on its plans for doing so.\nAs a result of this Congressional request, PHMSA worked with a number of stakeholder\ngroups to evaluate IM requirements that could be applied to distribution pipelines in a\npractical manner. This program was described in DOT's report to Congressl as the first\nphase of a multi-phased effort. The Phase 1 program has now been completed, and has\nOffice of Pipeline Safety, Pipeline and Hazardous Materials Safety Administration, Department of\nTransportation, \"Assuring the Integrity of Gas Distribution Pipeline Systems: A Report to the Congress,\" May\n2005.\n\n<<<PAGE 2>>>\n\nreached conclusions about the nature of IM programs that could be required of distribution\npipeline operators.\nThe Phase 1 program concluded that it would be most appropriate to require IM programs of\ndistribution pipeline operators through a high-level regulation that permits significant\nflexibility. Such a structure will best accommodate the wide diversity among distribution\npipeline operators. Companion guidance is needed to enable operators and the public to\nunderstand better the actions that must be taken to implement the regulation, preferably\nproviding options suitable for different circumstances faced by different operators. It would be\nmost useful if this guidance were developed in parallel with the regulation, so that public\ncomment on a proposed rule could be informed by the additional information that would be\nprovided by the guidance. It is for this reason that PHMSA and NAPSR are requesting that\nGPTC undertake an effort to develop the needed guidance. We hope you share our sense of\nurgency for developing guidance to support implementation of final rule anticipated by late\ncalendar year 2007.\nThe Phase 1 program, as described in the Phase 1 report, concluded that a high-level flexible\nregulation for distribution IM should include seven elements:\n1.\n2.\n3.\n4.\n5.\n6.\n7.\ndevelopment of a written IM plan\nassuring an understanding of an operator's infrastructure\nidentifying applicable threats, both current and potential\nanalyzing risks\nimplementing appropriate measures to address risks\nmeasuring performance and adjusting the IM program as needed\nreporting selected results to regulatory authorities on a periodic basis.\nGuidance is needed for implementing these elements. In particular, guidance is needed to\naddress:\n•\n•\n•\n•\n•\n•\n•\nInformation that an operator should gather through its routine activities to improve\nthe understanding of its distribution system infrastructure\nHow best to assemble detailed information on pipe characteristics (including material,\nmanufacturer, batch, etc.) into an operator's understanding of its system to support\ncurrent and future risk management activities\nThreat evaluation processes and data needed to support this evaluation\nOptions for evaluating the relative importance of threats\nHow risk analysis can be performed, encompassing situations from small, simple\ndistribution systems to those that are large and complicated, and what use should be\nmade of the results of these analyses\nChoices for decision processes and criteria for selecting prevention, detection and\nmitigation measures\nChoices for measuring safety program effectiveness and describing the situations\nunder which the measures would be meaningful\n\n<<<PAGE 3>>>\n\n• Choices an operator might make in evaluating the overall effectiveness of its program\n(e.g., how to determine it is being implemented as described; how to determine\nwhether it is producing improvements)\nIn addition, specific guidance is needed to address:\n•\n•\n•\nCriteria for determining whether it is feasible to install an excess flow valve (EFV) in\na gas service line (i.e., would a valve work reliably if installed?)\nRisk factors, and a risk evaluation approach, for determining when it is appropriate to\ninstall an EFV in a gas service line where installation is feasible (i.e., should a valve be\ninstalled?)\nImplementing a comprehensive leak management program, which is fundamental to\nsuccessful management of distribution risk, and thus is a vital risk control practice.\nAt a minimum, guidance is needed to implement the LEAKS program described in\nthe Phase 1 report for\no\ndetermining how local conditions and system knowledge should affect the\nfrequency and type of leak surveys\no\no\nmethods/criteria for evaluating the severity of leaks and need for action\nrecords that should be maintained to permit trending and identification of\nunderlying problems\no\nperfoiniance metrics and the types of analyses in which they should be\nconsidered\nThe wide diversity among distribution pipeline operators will likely make it difficult to\ndevelop the necessary guidance. In particular, the guidance must be useful to operators of\ndifferent size and with differing degrees of available resources and expertise. Many operators\nof distribution pipeline systems are small companies or municipal agencies, many without\nresources to develop custom IM plans or implementing procedures. These operators need\ndetailed guidance, but guidance that includes enough options so that they will fit their\nindividual circumstances. PHMSA and NAPSR considers that it would be useful for GPTC to\nestablish a separate committee for this effort, or to augment its existing committee in a manner\nthat will increase the participation by persons with expertise in the operation of small\ndistribution pipeline systems, as well as by federal and state safety regulators. PHMSA and\nNAPSR look forward to discussions with GPTC concerning how the involvement of\nappropriate expertise can be assured.\nASME/ANSI B31.8S, Supplement to B31.8 on Managing System Integrity of Gas Pipelines,\nprovides guidance for implementing the IM regulation for gas transmission pipelines. The\nportions of this document dealing with inspection/assessment will have no applicability to\ndistribution pipeline integrity management, but the portions addressing other elements of the gas\ntransmission IM regulation could provide a useful reference for developing applicable\nguidance for distribution pipelines.\n\n<<<PAGE 4>>>\n\nPHMSA and NAPSR would appreciate the opportunity to meet with GPTC to discuss further\nplans for the expeditious development of the guidance necessary to implement IM requirements\nfor gas distribution pipelines.\nPlease address any correspondence regarding this request to Mike Israni, PHMSA, and to\nDon Martin, NAPSR.\nSincerely,\nStacey Gerard Don Martin\nActing Assistant Administrator/Chief Safety Officer NAPSR National Chair","truncated":false,"body_characters":8519}