Technical Advisory Committee December 2012 Fitness for Service

Is not defined in the Code of Federal Regulation. Is not a term of art with legal consequences. Is defined in a API standard that is not relevant to pipelines. Some have tried to apply the concept of FFS to pre-1970 transmission pipe. There are many definitions for “fitness for service”, so the phrase is very open to many interpretations and is of limited beneficial to use in a regulatory discussion. Operators are not going to knowingly operate pipe that is not fit for service. AGA developed definitions for transmission and distribution fitness for service to provide some framework for a term used liberally by DOT officials. The AGA definitions are based upon regulations in 49 CFR 192 and processes unique to the state regulatory system.

Transmission Fitness for Service New construction component Existing construction component Integrity management assessment component for high consequence areas Integrity management component for low stress pipelines Results in decisions to repair, rehabilitate, change operating conditions or replace the pipe.

Transmission Fitness for Service New construction regulations Design specifications Construction verification Post-construction pressure test Existing construction regulations Determined by continuing surveillance, and relevant sections of 49 CFR 192 Subpart O for HCAs and similarly situated areas Subpart O recognizes low stress pipelines.

Pre-1970Transmission Fitness for Service The fitness for service of pre-1970 pipe is not merely a safety issue, it is a national energy security issue that is far beyond the capacity of PHMSA to address by itself. Significant portions of the nation’s energy delivery system may be taken out of service or abandoned. SEC. 27. MAXIMUM ALLOWABLE OPERATING PRESSURE. …“The Secretary, in consultation with the Chairman of the Federal Energy Regulatory Commission and State regulators, as appropriate, shall establish timeframes for the completion of such testing that take into account consequences to public safety and the environment and that minimize costs and service disruptions. From the Pipeline Safety Act of 2011

Distribution Fitness for Service There is a large diversity of material, pipe sizes, and operating conditions in the distribution system. Cast iron Bare Steel Coated and cathodically protected steel Polyvinyl chloride plastic Polyethylene plastic Copper Other materials Tees, fittings, caps and other appurtenances Typically operates at pressure of a few inches of water to 60 psi. Some high pressure mains may operate at 125 psi.

Distribution Fitness for Service New construction regulations Design specifications Construction verification Post-construction leakage test Existing construction regulations Continuing surveillance 192 subpart P – Distribution IMP HCAs not needed as DIMP requires the entire system to be assessed. Risks are generally higher frequency, lower consequence. Additional and accelerated measures required in DIMP.

Local distribution companies use all of the assessment tools discussed to determine the “fitness for service” of the transmission and distribution pipe in the system. Decisions are made to repair, rehabilitate, change operating conditions, or replace pipe. The state regulatory system is structured to be very transparent and operators provide a summary of the decisions to regulators and the public during rate cases. Operators are responsible for safety performance, but they seek approval from utility commissions for rate recovery. Distribution Fitness for Service

Summary Local distribution companies use Smart Modernization to target the risk-based repair, rehabilitation or replacement of specific facilities or groups of facilities (transmission and distribution pipe) based on the condition and performance of those facilities.

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