Plastic Pipe Rule – Tracking and Traceability Proposed Requirements AGA T&T Workshop October 12, 2016 Max Kieba Engineering & Research Division 202-493-0595 Office of Pipeline Safety max.kieba@dot.gov

A. Tracking and Traceability Issue: Not all operators have consistent data to identify systemic issues related to plastic pipe and fittings DIMP requires knowing location and material but inconsistencies in implementation Once a pattern of problems is identified, many operators cannot locate the items of concern within their systems items of concern could be related to materials, people (qualification), and/or procedures (Good issues): Industry worked together for years on the T&T standard and others that should have been incorporated years ago Many of the 2012 versions of key material standards have the T&T standard incorporated within them

T&T Proposal - Definitions In §192.3 – definitions for tracking and traceability information based on definitions in applicable standards + additional information (e.g. person who made joint) Comments to the rule and discussion at advisory committee on issues with Traceability information definition

T&T proposal – IBR standards In §192.7 - Incorporate by reference (IBR) ASTM F2897–11a IBR approved for §§ 192.3 and 192.63(e). Material specifications that include F2897 (IBR approved for Item I, Appendix B to Part 192 – Qualification of Pipe and Components) ASTM D2513–12ae1 for PE ASTM F2785–12 for PA-12 ASTM F2945–12a for PA-11

T&T Proposal – marking/records NPRM Proposal – subject to change § 192.63 Marking of materials. *** (e)(2) Plastic pipe and components manufactured after [INSERT EFFECTIVE DATE OF FINAL RULE], must be marked in accordance with ASTM F2897 (incorporated by reference, see § 192.7) in addition to the listed specification. (3) All markings on plastic pipelines prescribed in the specification and paragraph (e)(2) shall be legible, visible, and permanent in accordance with the listed specification. Records of markings prescribed in the specification and paragraph (e)(2) shall be maintained for the life the pipeline per the requirements of §§ 192.321(k) and 192.375(d).

Records cont’d § 192.321 (k) (Installation of plastic pipelines) and § 192.375 (d) (Service lines: Plastic) Tracking and Traceability. Each operator must maintain records for tracking and traceability information (as defined in § 192.3) for the life of the pipeline.

A. Tracking and Traceability: Comments Support Drop Suggested PHMSA should drop this from the rule and pursue a separate tracking and traceability rulemaking for all materials Claimed that the requirements would be economically significant. Permanence Markings are primarily for capturing tracking and traceability information at installation Suggested that permanent records of markings could be considered equivalent to permanent markings Alternatives- Markings must be “legible”, “visible”, and/or “readable”; For 20 years Until the time of installation Potentially burdensome to small public operators ASTM F2897 - Redefine tracking and traceability to only what is required required in ASTM F2897, and pursue any additions via the standard development process Timeline - Recommend phase in, ranging from 2-5 years Multiple entities submitted comments that markings should only have to remain visible until the time of installation. Truly "permanent" markings are not currently technically feasible, and the information is only needed at the time of installation, afterwards the information has been inputted into GIS or other data systems, the physical markings are no longer necessary. PPI notes that with current technology and practice, markings are designed to last for 3 years within an underground environment APGA believes permanent would be significantly burdensome to small public operators, and proposes 20 years after manufacture to be a reasonable timeframe. commendation combined with NAPSR Resolution (50 year markings)

Advisory Committee discussion Marking – One Year: Committee did not oppose PHMSA recommended 1 year phase in for the marking requirements Legible until installation reasonable Recordkeeping – Committee discussion for extended timeline Even though T&T record keeping could potentially be done manually (i.e. record 16 digit number on piece of paper) it is an inefficient process… going to a more electronic means is the way to go to do it right Various cost, complexity concerns for integration into existing processes which vary from operator to operator More time could help figure out a way to do it as effectively as possible

§ 192.3– discussion w/ committee NPRM Version § 192.3 Definitions * * * * * Traceability information means data that is provided within ASTM F2897-11a (incorporated by reference, see § 192.7) that indicates within the unique identifier, at a minimum, the location of manufacture, production, lot information, size, material, pressure rating, temperature rating, and, as appropriate, type, grade and model of pipe and components Possible Changes § 192.3 Definitions * * * * * Traceability information means data that is provided within ASTM F2897-11a (incorporated by reference, see § 192.7) that indicates within the unique identifier, the origin of materials used to manufacture a given component and/or the product processing or manufacturing history including component manufacturer, manufacturer’s lot code, production date, material, component type, and size.

Tracking Information Tracking information means data that provides for the identification of the location of pipe and components, the date installed, and the person who made the joints in the pipeline system.

192.63 discussion w/ committee § 192.63 Marking of materials. (a) Except as provided in paragraph (d) of this section, each valve, fitting, length of pipe, and other component must be marked as prescribed in the specification or standard to which it was manufactured. * * * * * (e) Additional requirements for plastic pipe and components. (1) All markings on plastic pipe prescribed in the listed specification and the requirements of paragraph (e)(2) shall be repeated at intervals not exceeding 2 feet. (2) Plastic pipe and components manufactured after [insert [One Year After?]effective date of final rule] , must be marked in accordance with ASTM F2897 (incorporated by reference, see § 192.7) in addition to the listed specification. (3) All markings on plastic pipelines prescribed in the specification and paragraph (e)(2) shall be legible, visible, and permanent in accordance with the listed specification. After [insert [X Years After?] effective date of final rule] records of markings prescribed in the specification and paragraph (e)(2) shall be maintained for the life the pipeline per the requirements of §§ 192.321(k) and 192.375(d).

Discussion by advisory committee -Recordkeeping compliance extended from 2 to 5 years -The marking is legible until installed -The traceability definition in 192.3 is limited to the categories in the standard (F-2897)

Additional Info GPAC meeting presentations and transcript: https://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=113 Docket PHMSA-2014-0098 (www.regulations.gov) US DOT provides a monthly status report on Significant rulemakings and link to semi-annual regulatory agenda for all rulemakings (including nonsignificant) at https://www.transportation.gov/regulations/report-on-significant-rulemakings Plastic Rule Regulation Identifier Number (RIN) 2137-AE93

Current Status of rule Final rule under development at PHMSA Designation request (significant or non-significant) TBD If stays non-significant: Targeted for fall/winter of 2016 If significant: ?

Max wish list items Anything we can do collectively with certificate(s) of conformance, T&T attributes (such as lot code?), or other inspection records for consistency in key information like: Temperature/HDB ratings (particularly as we start seeing materials with higher ratings) UV exposure/outdoor storage stability Pressure ratings (could help with verification of MAOP, consideration for changes in design pressure limit, and/or as plastics are considered (used) for higher pressure applications)

Questions? Max Kieba 202-493-0595 max.kieba@dot.gov