1. AGA Positions on Current PHMSA Rulemakings
September 2015
AGA Positions on Current PHMSA Rulemakings

2. Current PHMSA Pipeline Safety Initiatives
Miscellaneous Final Rule
Plastic Pipe Rule Notice of Proposed Rulemaking (NPRM)
Operator Qualification, Cost Recover, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes (NPRM)
Excess Flow Valves In Applications Other Than Single-Family Residences in Gas Distribution Systems (NPRM)
National Pipeline Mapping System

3. Miscellaneous Final Rule
Published: March 11, 2015
Effective Date: 10/1/15 (will be delayed until 1/1/16 or later)
Major Topics:
performance of post-construction inspections
requirements for qualifying plastic pipe joiners
the transportation of pipe
Petitions for Reconsideration:
AGA – Request to Extend Effective Date of (Construction Inspection) to 1/1/16
AGA & INGAA – Request for Reconsideration: Components Fabricated by Welding
APGA – Request for Reconsideration: Construction Inspection
Construction Advisory Group (PHMSA, NAPSR, AGA, APGA) working on a solution to

4. AGA’s Position on Construction Inspection
Frequently Asked Questions
What pipelines are covered by § ?
Transmission Lines & Distribution Mains
Are construction activities associated with the installation of service tees covered by § ? No
What construction activities are covered by § ?
Currently, just activities regulated by Subpart G. The Advisory Group is working to expand the regulation to all construction tasks on transmission lines or distribution mains that require inspection. The group is focused on creating a risk based solution that does not dramatically increase the burden (resource/paperwork) on operators or contractors. Concentration: Construction activities where you have limited opportunities to correct a mistake once the line is buried. NOTE: To expand the regulation past Subpart G, PHMSA will need to issue a new regulation

5. Plastic Pipe – Notice of Proposed Rulemaking
NPRM Published – 5/21/2015
Comments Were Due – 7/31/2015
Supported: Increased PE Design Factor, Use of PA-11/12
Tracking & Traceability
Separate from Plastic Pipe Rule – Significant & Costly
Remain consistent with ASTM F2897
Phased Implementation
Plastic Pipe Installation
Backfill & Trenchless Technology
Qualification of Joining Procedures & Persons Making Joints
Retroactive Regulations
Risers
Mechanical Leak Repair Clamps

6. OQ, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Changes - NPRM
NPRM Published – 7/10/2015
Comments Were Due – 9/8/2015
Operator Qualification
OQ for New Construction
Change Management Program
Effectiveness of OQ Programs
Accident and Incident Notification
Cost Recovery for Design Reviews
Special Permit Renewal
Gathering Lines
Pressure Regulation Inspection
Drug / Alcohol Testing

7. Excess Flow Valves In Applications Other Than Single-Family Residences in Gas Distribution Systems - NPRM
NPRM Published – 7/15/2015
Comments Were Due – 9/14/2015
EFVs on multi-family residences and single, small commercial customers
With known customer loads not exceeding 1,000 SCFH per service, at time of service installation
Notifications
A customer’s right to request an EFV
Within 90 days of the customers first receiving gas at a particular location
Manual Service Line Shut-off Valves
Any new or replaced service line, with installed meter capacity exceeding 1,000 SCFH.
Installed in such a way to allow accessibility during emergencies.

8. National Pipeline Mapping System
Comments on Proposal #1: Submitted Q4 2014
Estimated Publication of Proposal #2: Fall 2015
AGA supports:
Modernization of the NPMS
Narrowing of positional accuracy requirements
Modifications that improve pipeline safety
AGA does not support:
Positional accuracy of 5 feet for Class 3, 4 & HCAs
Requirement for all 31 proposed pipeline attributes
Estimated timeframe to comply by PHMSA

9. Safety of Gas Transmission and Gathering Lines
NPRM Awaiting Publication - Currently at OMB
Major Topics under consideration:
Expansion of IM requirements beyond HCA’s
Repair criteria for both HCA and non-HCA areas
Assessment methods
IVP – Grandfathered pipe/pipe records/legacy pipe/pipe tested below 1.1 MAOP
AGA does not support:
Re-verification of MAOP where a pressure test was performed
Cutting coupons for material record verification
Universal requirement of spike testing
The introduction of Medium Consequence Areas (MCAs)
High Stress Lines equaling > 20% SMYS
AGA supports pressure testing untested PLs operating above 30% SMYS in Class 3, 4 & HCAs; meeting the mandates of the Pipeline Safety Act of 2011

10. Rupture Detection and Valves
NPRM In Development
Expected to Cover:
Rupture detection and response time metrics, including integration of ASV and RCV placement (Objective: Improve overall incident response)
Will attempt to address:
Legislation: If appropriate, require ASVs, RCVs or equivalent technology on new or fully replaced transmission lines (where economically, technically & operationally feasible)
NTSB Recommendations on valves and leak detection: Equip SCADA systems with tools to assist in recognizing and pinpointing leaks (distribution and transmission)
AGA Members are Taking Action:
Evaluate use of ASVs and RCVs on Transmission HCA block valves

11. Find Us Online Christina Sames VP, Operation & Engineering
Christina Sames
VP, Operation & Engineering