Operator Qualification John Erickson, PE American Public Gas Association

ASME B31Q

B31Q Published in 2005 Non-mandatory national standard Includes covered task list and abnormal operating conditions for tasks Covered both gas and liquid pipelines Covers natural gas distribution Currently under review for updating

Issues Include new construction in covered tasks How does training fit in? When is training necessary?

Training - Examples A covered task not previously performed; Covered task outside knowledge and skills; Qualification suspended or revoked; Fails an evaluation for qualification; New or different knowledge or skills to perform a covered task; New equipment or procedures

When B31Q is revised Still no plans for PHMSA to incorporate B31Q into pipeline safety regulations B31Q does provide a framework for both regulators and regulated to gauge OQ programs

OQ Enforcement

PHMSA Summary from 2006 ~ 15% of operators inspected had no OQ program Several operators were identified that do not address AOCs Some instances were found where covered tasks were being performed by non-qualified individuals Some operators failed to verify the qualifications of contractors

Continued Covered task list missing or incomplete Knowledge-based, with no evaluation of skills Omitted reevaluation intervals or failed to support intervals used (many intervals were 3 years for consistency with OSHA training requirements) Documentation was often insufficient to support demonstration of compliance

Protocol Nine Inspectors are checking field activities to O&M procedures and OQ evaluations Are tasks performed as described in the O&M plan and evaluated as in OQ plan? Georgia cited all systems for non-compliance – fines > $100,000 Georgia operators are rewriting their O&M procedures to match OQ requirements

APGA Security and Integrity Foundation (SIF)

APGA Security and Integrity Foundation (SIF) Created in 2005 Funded by PHMSA Cooperative Agreement Provides programs to assist small systems to operate safely and in compliance Operator qualification evaluations Operations and Maintenance procedures DIMP Model plan

OQ Evaluations Evaluations in 49 covered tasks (using B31Q) Both written and hands on evaluation Addresses general and task specific AOCs Evaluation tools reviewed by an industry/regulator advisory group Evaluations help close to small operators

Over 1100 evaluated in 13 states

Next program Sept 8-12 at Leak City

O&M Procedures Exactly match SIF OQ evaluations Individual task procedures that can be part of an O&M Plan List of required tools and supplies Worker safety issues identified Step-by-step procedures Advice for “AOC’s” Cross references to related task procedures

O&M Procedures Developed by SIF staff, contractors, MGAG and Austell Gas system Reviewed by an industry/government panel Available for free download at www.apgasif.com New PHMSA extension funds development for remaining B31Q distribution tasks

Questions? jerickson@apga.org 202-464-0834 www.apga.org