1. Operator Qualification
John Erickson, PE
American Public Gas Association

9. ASME B31Q

10. 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

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

12. 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

13. 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

14. OQ Enforcement

15. 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

16. 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

17. 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

18. APGA Security and Integrity Foundation (SIF)

19. 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

20. 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

21. Over 1100 evaluated in 13 states

22. Next program Sept 8-12 at Leak City

23. 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

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

25. Questions?