1. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration NPRM; Miscellaneous Changes to Pipeline Safety Regulations - 1 -

2. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Background November 29, 2011 published a Notice of Prosed Rulemaking entitled “Miscellaneous Changes to Pipeline Safety Regulations. –At the end of this presentation we will be asking for you to provide us your recommendation on this rulemaking. NPRM proposed 17 separate amendments to the pipeline safety regulations. - 2 -

3. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Why the Miscellaneous changes? Proposals were as a result of petitions for rulemaking from Trade Associations, National Association of Pipeline Safety Representatives (NAPSR), internal recommendations and a Recommendations from the NTSB. Proposals were also intended to correct errors, and address inconsistencies. Amendments would impose minimal burden (if any) and were so minor to not merit a separate rule - 3 -

4. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Topics covered in the Miscellaneous Rule 1. Responsibility to Conduct Construction Inspection 2. Leak Surveys for Type B Gas Gathering Lines 3. Qualifying Plastic Pipe Joiners 4. Mill Hydrostatic Tests for Pipe to Operate at Alternative MAOP 5. Regulating the Transportation of Ethanol by Pipeline 6. Limitation of Indirect Costs in State Grants 7. Transportation of Pipe 8. Threading Copper Pipe - 4 -

5. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Topics covered in the Miscellaneous Rule 9. Offshore Pipe Condition Reports 10. Calculating Pressure Reductions for Hazardous Liquid Integrity Anomalies 11. Testing Components other than Pipe Installed in Low- Pressure Gas Pipelines 12. Alternative MAOP Notifications 13. National Pipeline Mapping System 14. Welders vs Welding Operators 15. Components Fabricated by Welding 16. Odorization of Gas 17. Editorial Amendments

6. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Comments Received Received 43 of comments to the NPRM. Most comments dealt with »Construction Inspection »Odorization » Qualifying Plastic Pipe Joiners - 6 -

7. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Proceeding with A Vote Rule - Less those items members have requested a separate vote –Brief –Members will be given an opportunity to comment after each topic –Public will be given an opportunity to comment after the completion of the brief –LPAC and GPAC will vote separately - 7 -

8. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Proceeding with A Vote Those items members have requested a separate vote –Brief –Members will be given an opportunity to comment –Public will be given an opportunity to comment –LPAC and GPAC will vote separately (and as appropriate) - 8 -

9. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Proceeding with A Vote Those proposals members have requested a separate vote are : –Construction Inspection (GPAC and LPAC) –Odorization (LPAC) –Qualifying Plastic Pipe Joiners (GPAC) –Limitation of Indirect Costs to States (GPAC) (LPAC) –Pressure Reductions for Hazardous Liquid Pipeline Integrity Anomalies (LPAC) - 9 -

10. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Minor Proposals Several items were either purely editorial or minor in scope and controversy: –These items included: Editorial changes Threaded copper pipe Ethanol Elimination of the off-shore condition reports Testing components in LS pipelines Welding vs. Welding Operators - 10 -

11. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Leak Survey for Type B Gathering Lines Leak Survey for Type B Gathering Lines Proposed to require Type B Gas Gathering Lines to be subject to leak survey requirements in accordance with § 192.706 Type B Gas Gathering lines are metallic lines with MAOP of less than 20% of SMYS, non-metallic lines with MAOP of 125 psig or less. Subject to less stringent requirements than Type A gas gathering lines Are located in Class 2, Class 3 or 4 location. - 11 -

12. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Leak Survey for Type B Gathering Lines Proposal based upon a recommendation from NAPSR Gas leaks are a primary hazard from low-stress lines Operators had to perform leak surveys in non-rural areas prior to March 2006 rule - 12 -

13. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Leak Survey for Type B Gas Gathering Lines; Comments PHMSA should not move forward with additional regulatory language when Congress (Section 21 of 2011 Reauthorization Act) had mandated a review of the sufficiency of existing regulations of gathering lines. Have greater impact on operators and impose greater burden than PHMSA has considered. No supporting data for proposed change Economic impact may exceed the threshold for insignificant regulatory action. Docket has no supporting evidence to show facts and not speculation. - 13 -

14. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Leak Survey for Type B Gas Gathering Lines; Comments Develop estimates of the cost of compliance for affected operators. PHMSA must provide at least one year adequate time for operators to purchase equipment, develop recordkeeping system and hire new personnel following adoption. Require compliance with the leak survey requirements in 192.723 (leak surveys for distribution lines) and not 192.706 (leak surveys for transmission lines) - 14 -

15. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Transportation of Ethanol by Pipeline Proposed to modify the definition of hazardous liquid (49 CFR 195.2) to include ethanol, and to subject such transport to regulations contained in 49 CFR Part 195. Consistent with policy statement published on August 10, 2007 dealing the transportation of ethanol and other bio- fuels by pipeline Comments were supportive - 15 -

16. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Transportation of Pipe Certain pipe must be transported by railroad in accordance with API 5L1. However, an exception allows operators to use pipe stockpiled prior to November 12, 1970. NTSB recommends that all pipe be transport in accordance with the API 5L1 standard. –During its investigation of a July 2002 incident, NTSB found that growth of a fatigue crack introduced during transport was a causal factor. Proposed to eliminate the exception to use pipe stockpiled prior to November 12, 1970. - 16 -

17. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Transportation of Pipe Comments were supportive but asked for clarification, such as: –With proper documentation of API 5LI, allow operators to use pipe transported prior to November 2, 1970. –Proposed wording may result in nuances of misinterpretation that “use” applies to pipe currently installed rather than pipe in stock. - 17 -

18. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Threading Copper Pipe Gas Piping Technology Committee (GPTC) advised PHMSA that Table C1 was deleted in the most recent version of ASME/ANSI B16.5 (Incorporated by reference). PHMSA proposed to incorporate the suggested reference to ASME B36.10M in §192.279. No negative comments were received.

19. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Offshore Pipeline Condition Reports In December 1991, established inspection and reporting requirements for pipelines in the Gulf of Mexico and inlets. (191.27 and 195.57) In August 2004, final rule amended the PSR to require operators to prepare and follow written procedures for the inspections and repair, and to promptly report and rebury any line found exposed or hazardous to navigation. (§192.612 and §195.413) –Did not repeal the reporting requirements in 191.27 and 195.57 - 19 -

20. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Offshore Pipeline Condition Reports Reporting requirement in §192.612(c) and §195.413(c) is sufficient to meet PHMSA’s current information collection needs. Accordingly, PHMSA is proposing to repeal §§192.27 and 195.57. No comments received against proposed change to regulation. - 20 -

21. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 21 The PSR provide an exception from the strength test requirements for components installed in pipelines operating at or above 30% percent SMYS. –The manufacturer has to certify that: The component was tested to at least the pressure required for the pipeline. The component we manufactured under a QC system The component carries a pressure rating. Testing Components other than Pipe Installed in Low- Pressure Gas Pipelines

22. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Testing Components other than Pipe Installed in Low-Pressure Gas Pipelines GPTC petition to request that the exception be expanded to include pipelines operating below 30% SMYS. Comments were in favor to the proposal and requested some editorial amendments. - 22 -

23. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 23 Alternative MAOP Notifications Operators must notify PHMSA/State 180- days prior to commencement of operations if electing to establish and operate at a higher than Maximum Allowable Operating Pressure. PHMSA proposes to require 180-days notice prior to pipe manufacturing and/or construction activities also. This notice would allows for PHMSA/State review of applicable procedures, specifications, field reviews, operations and maintenance plans and other documentation.

24. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Alternative MAOP Notifications Proposal should apply only prospectively, and the regulation should include an alternative notice period measured from the placement of the pipe purchasing order to the start of pipe manufacturing. Language needs clarification with regard to new pipe. If operator wishes to utilize existing pipe stock that satisfies the MAOP regulation requirement, 180 days notice to manufacturer would be impossible. Such “gotcha” language should not be part of regulation. Revise language or remove “and/or” and provide clear unambiguous standards. - 24 -

25. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration National Pipeline Mapping System The National Pipeline Mapping System is a geospatial dataset containing information on all PHMSA-regulated pipelines, and data layers for all liquefied natural gas plants and a partial dataset of PHMSA regulated breakout tanks. Proposed to add to the PSR the statutory requirements related to submission of NPMS data to PHMSA. The NPMS data submissions became mandatory under the Pipeline Safety Act of 2002. Submissions will be done concurrently with the appropriate annual report. Comments were supportive of the proposal, some making editorial type recommendations - 25 -

26. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Welders Vs Welding Operators Proposal to add references to applicable sections of Parts 192 and 195 to clarify the qualification standards of welding operators. PHMSA expects qualified welder/welding operator to operate consistent with federal regulations and applicable ASME and API standards. Comments were supportive with some commenters requesting editorial changes or clarification. - 26 -

27. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Mill Hydrostatic Tests for Pipe to Operate at Alternative MAOP Proposal to revise §192.112(e)(1) by eliminating allowance for combining loading stresses imposed by pipe mill hydrostatic testing equipment for the mill test. Section 192.112 applies to pipe that will operate at the higher stresses allowed under the alternate MAOP. Combined with pipe mill dimensional checks for expansion, will help assure that all new pipes for this service receive an adequate mill test and have adequate strength. - 27 -

28. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Mill Hydrostatic Tests for Pipe to Operate at Alternative MAOP; Comments Consult with pipe manufacturers regarding potential impacts of consideration of end loading in the calculation of mill hydrostatic test before adopting changes to procedure. Increased safety factor already added in final rule amendment of Part 192(PHMSA-2005-23447) in October 2008. System operating pressures vary based on season, system configurations and maintenance. Line may rarely see MAOP. - 28 -

29. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote Both committees must motion and vote separately. Sample language: –The proposed rule as published in the Federal Register (except for proposals Number 1, 3, 6, 10, 15, and 16) is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 29 -

30. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Components Fabricated by Welding The pressure test requirements in the recent ASME Boiler and Pressure Vessel Code (BPVC) Section VIII were lowered from a test factor of 1.5 to 1.3. This revision created a difference in the pressure testing requirements in ASME BPVC and the test requirements in 192.505(b) which requires a test factor of 1.5 times MAOP for meter and compressor stations as well any other Class 3 location. PHMSA proposed to add a clarification to §192.153 to clearly specify the design and test (factor of 1.5) requirements for pressure vessels in meter stations, compressor stations, and other locations that are tested to Class 3 requirements. - 30 -

31. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Components Fabricated by Welding Commenters did not agree that this was clarification and believed that this was a significant change in the Code. Clarify that the amendment applies only to components placed into service after the amendment’s effective date. Without grandfathering, many facilities constructed after change in ASME BPVC will result in costly replacements. Change to regulations has far-reaching impact. Retesting or replacing these in-service components would be unnecessary, very expensive and take several years to complete. - 31 -

32. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote Both committees must motion and vote separately. Sample language: –The proposed rule as published in the Federal Register related to components fabricated by welding is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 32 -

33. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Odorization of Gas 49 CFR 192.625 requires operators to odorize combustible gas in a transmission line in Class 3 or Class 4 locations. Certain exceptions are provided including for a “lateral line “which transports gas to a distribution center {if} at least 50 percent of the length of that line is in a Class 1 or Class 2 location. Proposed to revise the exception to state that the length of a lateral line for purposes of calculating whether at least 50 percent of the lateral line is in Class 1 or Class 2 is measured between the distribution center and the first upstream connection to the transmission line. - 33 -

34. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Odorization of Gas; Comments Distinction between lateral and transmission line appear to lack logic as it allows parts of a line originally considered to be a “lateral” line to change classification due to introduction of a branch. Cost not justified. Statistical evidence not presented to show that this understanding of lateral line has caused safety issues resulting from operators applying this definition to exempt certain lines from odorization under §192.625(b)(3). Pending further study, and impact assessment, do not adopt the proposal - 34 -

35. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Odorization of Gas; Comments Sulfur dioxide emissions will unfavorably impact ambient air quality in areas that are nonattainment for particulate matter or SO 2. Would impose great burden on operators Residual odor on end products making the product unsuitable for use, or negatively affecting the commercial value as well as residual odorant in air emissions resulting in false reports. Should not adopt the proposal but convene a public hearing or workshop where various configurations can be evaluated - 35 -

36. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote § 192.625 Odorization of Gas ***** (b) *** (3) In the case of a lateral line which transports gas to a distribution center, at least 50 percent of the length of that line is in a Class 1 or Class 2 location as measured between the distribution center and the first upstream connection to the transmission line; ***** - 36 -

37. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote GPAC only Sample language: –The proposed rule as published in the Federal Register related to odorization of gas transmission lines is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 37 -

38. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Responsibility to Conduct Construction Inspections Proposed to revise §192.305 & §195.204 to specify that the construction inspection of a transmission pipeline or main cannot be cannot be conducted by a person participated in its construction. –Proposal applies to both contractor and non-contractor work Proposal was based in part on a petition from NAPSR - 38 -

39. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Responsibility to Conduct Construction Inspections NAPSR stated that: –resolution was intended to preclude operators from allowing contractor personnel to self-inspect their own work. –it was based on the experiences of NAPSR members concerned at that time with poor quality of construction by unsupervised contractors; –resolution does not propose mandatory third party inspection of all construction work

40. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Responsibility to Conduct Construction Inspections Comments received include but not limited to: Proposed rule will result in significant cost impact to operators. Overly burdensome economically and has the potential to compromise site safety due to additional personnel, congestion, inattention, carelessness and unnecessary overhead expenses. Proposed amendment is clearly a significant regulatory action and inappropriately included in a non-significant rulemaking. Remove proposed change and consider it in separate rule. - 40 -

41. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Responsibility to Conduct Construction Inspections Proposed language does not differentiate between and operator’s employee and a contractor’s employee. Clarify the meaning of a person “participating in the construction” of a pipeline. Make inspection and new construction OQ tasks. Prohibiting any “person” involved in the construction of a pipeline could be interpreted to prohibit any other municipal employee from performing inspection. Redefine “a person who participated” in the construction of the pipeline. - 41 -

42. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Responsibility to Conduct Construction Inspections § 192.305 Inspection: General Each transmission line and main must be inspected to ensure that it is constructed in accordance with this subpart. An inspection may not be performed by a person who participated in the construction of that transmission line or main. INGAA Language: A required inspection may not be performed by the individual who performed the construction task requiring inspection NAPSR Language: Each transmission line and main must be inspected to ensure that it is constructed in accordance with this part. No operator shall use a person to perform thee required inspections if that person is perfoning any construction activities subject to inspection. Nothing in this section should prohibit the operator from inspecting construction activities with operator personnel who are involved in the construction activities. - 42 -

43. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Agreed Upon Lange INGAA Language: A required inspection may not be performed by the individual who performed the construction task requiring inspection (§ 192.305) Modified NAPSR Language: Each transmission line and main must be inspected to ensure that it is constructed in accordance with this part. No operator shall use an individual to perform a required inspection if that individual performed the construction task requiring inspection. Nothing in this section prohibits the operator from inspecting construction activities with operator personnel who are involved in the construction activities. - 43 - TAC (Gas) Agreed Upon language (Wed, July 11, 2012) TAC (Liquid) Agreed Upon this language with applicable adjustments for 195.204 (Wed, July 11, 2012)

44. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Responsibility to Conduct Construction Inspections 195.204 Inspection – general. Inspection must be provided to ensure the installation of pipe or pipeline systems in accordance with the requirements of this subpart. No person may be used to perform inspections unless that person has been trained and is qualified in the phase of construction to be inspected. An inspection may not be performed by a person who participated in the installation of the pipe or pipeline systems INGAA Language: A required inspection may not be performed by the individual who performed the construction task requiring inspection - 44 -

45. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote Both committees must motion and vote separately. Sample language: –The proposed rule as published in the Federal Register related to construction inspection is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 45 -

46. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Qualifying Plastic Pipe joiners - 46 - PHMSA proposed to revised the plastic pipe joiner qualification requirements to state the following: A person must be re-qualified under an applicable procedure if: –During any calendar year (not exceeding 15 months) that person does not make any joints under that procedure; or –Any production joint is found unacceptable by testing under § 192.513. Proposal was based a petition from NAPSR.

47. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Qualifying plastic Pipe joiners; Comments Disqualify and retrain if one joint unacceptable during 12- month period is overly excessive and without reasonable explanation. No data to show that person who makes one unacceptable joint will make one more. Proposed rule not reflective of NAPSR proposal: –A person individual must be requalified under an applicable procedure once each calendar year at intervals not exceeding 15 months, or after any production joint is found unacceptable by testing under 192.513. - 47 - TAC Agreed Upon language (Wed, July 11, 2012)

48. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Qualifying plastic Pipe joiners How does one unacceptable joint determine that an individual is unqualified? Leave §192.258(c)(2) as is written, “3 or 3% whichever is greater”. Zero tolerance standard fails to take into consideration that all plastic pipe are required to be pressure tested before going into service. This provides additional layer of service. Analyze data on fusion failures, present the information to the public then determine how best to address issue. Language unnecessarily restrictive. - 48 -

49. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote Sample language: –The proposed rule as published in the Federal Register related to qualifying plastic pipe joiners is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 49 -

50. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Limitation of Indirect Costs in State Grants PHMSA reimburses the states for a portion of the costs incurred in administering their pipeline safety programs, and Congress appropriates these reimbursement funds on a regular basis. The Pipeline Enforcement and Safety Act of 2006 (PIPES Act) removed a provision that imposed a 20% cap on state grant expenses. PHMSA proposes to incorporate into the regulations a 20% limit on indirect expenses for grants to state pipelines. - 50 -

51. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Limitation of Indirect Costs in State Grants; Comments Commenters stated that the limit is arbitrary and capricious and may prevent recovery of legitimate costs of State participation in Federal/State pipeline safety program. OMB Circular A-87, in Part 6, Attachment E, includes examples of indirect cost calculations that produce results far in excess of 20%. No clear rationale why PHMSA should impose by rule. States have different methods of allocating costs within their budget. No basis is presented for punishing States that distribute a larger portion of their costs as indirect costs. - 51 - TAC Voted to Table this issue for later (Wed, July 11, 2012)

52. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote Sample language: –The proposed rule as published in the Federal Register related to limitation of indirect costs in State grants is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 52 -

53. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 53 Current Code 49 CFR 195.452 (h)(4)(i) § 195.452 Pipeline integrity management in high consequence areas. * * * * * (h) (4) * * * (i) Immediate repair conditions. An operator's evaluation and remediation schedule must provide for immediate repair conditions. To maintain safety, an operator must temporarily reduce operating pressure or shut down the pipeline until the operator completes the repair of these conditions. An operator must calculate the temporary reduction in operating pressure using the formula in Section 451.6.2.2 (b) of ANSI/ASME B31.4 (incorporated by reference, see §195.3). An operator must treat the following conditions as immediate repair conditions: *****

54. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (i) Immediate repair conditions. An operator’s evaluation and remediation schedule must provide for immediate repair conditions. To maintain safety, an operator must temporarily reduce the operating pressure or shut down the pipeline until the operator completes the repair of these conditions. An operator must calculate the temporary reduction in operating pressure using the formula in section 451.7 of ASME/ANSI B31.4 (incorporated by reference, see § 195.3), if applicable. If the formulas not applicable to the type of anomaly or would produce a higher operating pressure, an operator must use an alternative acceptable method to calculate a reduced operating pressure. An operator must treat the following conditions as immediate repair conditions: 2007 HL IMP Mods 1 Final Rule 54

55. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 55 Proposed language in Misc. Changes NPRM § 195.452 Pipeline integrity management in high consequence areas. (h) (4) * * * (i) Immediate repair conditions. An operator’s evaluation and remediation schedule must provide for immediate repair conditions. To maintain safety, an operator must temporarily reduce the operating pressure or shut down the pipeline until the operator completes the repair of these conditions. An operator must calculate the temporary reduction in operating pressure using the formulas in paragraph (h)(4)(i)(B) of this section, if applicable, or when the formulas in paragraph (h)(4)(i)(B) of this section are not applicable by using a pressure reduction determination in accordance with § 195.106 and the appropriate remaining pipe wall thickness, or if all of these are unknown a minimum 20 percent or greater operating pressure reduction must be implemented until the anomaly is repaired. If the formula is not applicable to the type of anomaly or would produce a higher operating pressure, an operator must use an alternative acceptable method to calculate a reduced operating pressure. An operator must treat the following conditions as immediate repair conditions:

56. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 56 § 195.452 Pipeline integrity management in high consequence areas. (h) (4) * * * (i) Immediate repair conditions. An operator’s evaluation and remediation schedule must provide for immediate repair conditions. To maintain safety, an operator must temporarily reduce the operating pressure or shut down the pipeline until the operator completes the repair of these conditions. An operator must calculate the temporary reduction in operating pressure using the formulas referenced in paragraph (h)(4)(i)(B) of this section. If no suitable remaining strength calculation method can be identified, a minimum 20 percent or greater operating pressure reduction, based on actual operating pressure for two months prior to the date of inspection, must be implemented until the anomaly is repaired. An operator must treat the following conditions as immediate repair conditions: API/AOPL Comment: TAC Agreed Upon language (Wed, July 11, 2012)

57. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Vote Sample language: –The proposed rule as published in the Federal Register related to calculating pressure reductions for hazardous liquid integrity anomalies is technically, feasible, reasonable, cost-effective, and practicable if the following changes are made (members insert language of proposed change). Use bold language only as appropriate) –The proposed rule as published in the Federal Register is not (or cannot be made) made technically, feasible, reasonable, cost-effective, and practicable. - 57 -