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

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

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 192.305 (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 192.305

AGA’s Position on Construction Inspection Frequently Asked Questions What pipelines are covered by §192.305? Transmission Lines & Distribution Mains Are construction activities associated with the installation of service tees covered by §192.305? No What construction activities are covered by §192.305? 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

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

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

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.

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

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

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

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