State-Industry Regulatory Review Committee Phase 2 – SIRRC II

SIRRC II - Background Joint NAPSR-AGA-APGA product Equal representation from States and Industry Addressed Parts J, K, and L of 192 Consciously avoided changes to transmission and gathering DeWitt Burdeaux participated as a consultant

SIRRC II - Focus From the co-chairs letter to Stacey Gerard: Eliminate confusing, ambiguous, and conflicting language Clarify the distinction of the sections and paragraphs applicable to transmission lines and those applicable to distribution lines Ensure code requirements for uprating and establishing the MAOP of distribution systems are clarified as a distinct set of rules. Eliminate confusing cross-references Simplify and facilitate compliance with rule provisions while ensuring safety is maintained or enhanced

SIRCC II – Commentary on Code Changes: Test Requirements Sets the minimum test pressure for mains and service lines at 90 psig or 1.5 times the intended MAOP, whichever is greater. Exempts replacement lengths of mains and service lines less than 45 feet installed by open trench or above grade from pressure test requirements as long as the pipe is leak checked at operating pressure and visually inspected. Specifies that test duration shall take into consideration volume of test segment. Specifies minimum duration for tests on lines operating above 125 psig but less than 30% SMYS. If a service line is disconnected and reconnected on the same day and remains under the control of the operator, the portion of the service line from the point of disconnection to the service line valve does not need to be tested. Except for customer owned service lines, records for all pressure tests shall be kept. Sets record retention to a minimum of six years for mains and service lines tested under

SIRRC II – Commentary on Code Changes: Uprating When uprating specifies pressure increases to target MAOP only. Specifies what must be included in review of the system prior to uprate. Eliminates initial leak survey prior to uprating. Adds an additional leak survey 10 to 30 days after last incremental pressure increase. Specifies that all leakage surveys required by this section shall be conducted using methods appropriate for the conditions encountered.

SIRCC II – Commentary on Code Changes: Operations Allows temporary operation above MAOP within limitations for emergency conditions beyond the control of the operator. Requires operators to investigate and take corrective action based upon the review if the system is operated above MAOP. Requires a leak survey if a system has been operating below 50% of its MAOP for 5 years or longer after increasing the pressure by 50% or 20 psig whichever is greater above the highest sustained operating pressure in the preceding five years.