1. Plastic Pipe Rule – Tracking and Traceability Proposed Requirements
AGA T&T Workshop
October 12, 2016
Max Kieba
Engineering & Research Division
Office of Pipeline Safety

2. 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

3. 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

4. T&T proposal – IBR standards
In § Incorporate by reference (IBR)
ASTM F2897–11a IBR approved for §§ and (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

5. T&T Proposal – marking/records
NPRM Proposal – subject to change
§ 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 §§ (k) and (d).

6. Records cont’d
§ (k) (Installation of plastic pipelines) and § (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.

7. 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 F 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)

8. 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

9. § 192.3– discussion w/ committee
NPRM Version
§ Definitions
* * * * *
Traceability information means data that is provided within ASTM F a (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 § Definitions * * * * * Traceability information means data that is provided within ASTM F a (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.

10. 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.

11. 192.63 discussion w/ committee
§ 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 §§ (k) and (d).

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

13. Additional Info
GPAC meeting presentations and transcript:
Docket PHMSA (
US DOT provides a monthly status report on Significant rulemakings and link to semi-annual regulatory agenda for all rulemakings (including nonsignificant) at
Plastic Rule Regulation Identifier Number (RIN) 2137-AE93

14. 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: ?

15. 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)

16. Questions?
Max Kieba