1. U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration www.dot.gov

2. PHMSA Update on New MAOP Regulation and PIPA Western Region Gas Conference Tempe, Arizona August 25, 2009 Christopher Hoidal Western Region Director Office of Pipeline Safety

3. PHMSA Regions

4. Objectives of Recent Rulemaking Outgoing Administration focused on resolving many of our rulemaking mandates from Congress and Pipeline Safety Reauthorizations. NTSB recommendations addressed. Collecting better data to aid agency decisions. Recurring special permits requests codified into regulations.

5. Alternate MAOP Rule Allows for an increase of maximum allowable operating pressure (MAOP) over that currently allowed (up to 80% of Specified Minimum Yield Strength in Class 1 areas) Applies to gas transmission lines Increases energy capacity while maintaining safety Requires additional design and construction considerations Requires higher level of maintenance and assessment Requires 180 day notice to Region about intent to use alternate MAOP level

6. Timeline Special permits were granted on a case by case basis Proposed rule developed to codify Special Permit conditions Notice of Proposed Rulemaking (NPRM) published March 12, 2008 Final rule published October 17, 2008 Final rule effective 60 days from date of publication…December 22, 2008

7. Two New Code Sections 192.112- Additional Design Requirements for Steel Pipe Using Alternative Maximum Allowable Operating Pressure 192.620 – Alternative Allowable Maximum Allowable Operating Pressure for Certain Steel Pipelines

8. Comparison of Material and Construction Control Existing Requirements MAOP Rule Requirements MaterialsGeneralPrescriptive Mill Hydrotest90% SMYS, 10 sec 95% SMYS, 10 sec Coating TypeGeneralNon-shielding

9. Comparison of Damage Prevention & Emergency Response Existing Requirements MAOP Rule Requirements ROW patrolsBased on class12 times per year Pipeline MarkersNot specifiedLine of Sight Depth of CoverNot required beyond original installation Conduct depth of cover surveys and restore as needed Automatic ValvesNot RequiredNeeded when response > 1 hour

10. Comparison of Corrosion Control Existing Requirements MAOP Rule Requirements Confirming Adequacy of CP CIS feasibilityWithin 6 months conduct CIS and Coating Survey Interference Current Surveys Not specifiedWithin 6 months of operation Time to remediate Not specifiedWithin 6 months of survey Test Station Spacing Not SpecifiedMaximum ½ mile spacing in HCA’s

11. Comparison Other Requirements Existing Requirements MAOP Rule Requirements ILI assessmentHCA areas onlyPrescriptive Requirements on Entire Segment Operator Qualifications Not req’d for construction Required for construction Overpressure Protection Limits to 110% of MAOP Limits to 104% of MAOP

12. Who is doing MAOP Increases in the West? Kern River Gas Transmission - special permit Kinder Morgan REX - special permit Two others strongly considering under new MAOP regulation: One will be a new pipeline. The other was commissioned in 2007.

13. Practical Difficulties Complying with MAOP Provisions Hydrostatic Test Pressure in Hilly Terrain Class Changes Half mile CP Test Station Spacing Completion of Coating Surveys, and Subsequent Investigative Digs Mill Certs for Older Pipelines Depth of Cover Survey & Documented Land Use

14. Pipe Quality Issues Quality of Steel Pipe has been recent concern Low strength coils or plates (X-70, X-80) Inconsistent chemical and mechanical properties Poor rolling practices at some mills See our Advisory Bulletin (PHMSA 2009-1048) Industry actions Enhanced QA/QC practices being adopted (INGAA pipe quality summit – strategies to improve pipe quality) Working with API, ASME to address Advisory Bulletin More hands on inspection at mill Moving more rolling of specialty steels to US

15. Increasing Protection on Pipelines in Populated Areas New MAOP regs focus on increasing overall pipeline safety (and efficiency) in remote areas through enhanced design and engineering. PIPA efforts focus on improving safety of pipelines in populated areas through controlled land use and education.

16. Pipeline and Informed Planning Alliance (PIPA) Through PIPA, PHMSA is engaging property developers, home builders, pipeline operators, Local, State and Federal government agencies to develop best practices for property development adjacent to transmission pipelines. Draft Report available addressing recommendations from three task teams. Final Report expected soon.

17. Task Team Objectives Protecting Communities What should pipeline safety stakeholders do, or avoid doing, adjacent to the pipeline ROW to reduce the risk to communities ? Protecting Transmission Pipelines What should pipeline safety stakeholders do, or avoid doing, on the ROW to reduce the risk to transmission pipelines? Communications How should the risks to transmission pipelines and communities be communicated to pipeline safety stakeholders?

18. Thank you!! Questions??