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Pipeline Personnel Qualification
ASME B31Q Update Presented by Jerry Schmitz, P.E. Southwest Gas Corporation B31Q Technical Committee Chair
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Historical Perspective
1999: PHMSA published Operator Qualification (OQ) rule 2002: NTSB labeled Operator Qualification as “unsatisfactory” 2003: PHMSA issued 13 areas they considered as gaps in the rule 2003: Four public meetings held to address the 13 issues 2003: ASME B31Q Project Team formed to develop a technically sound, holistic, consensus standard for the qualification of pipeline personnel 2005: PHMSA amended OQ rule to address training, on-the-job performance and reporting significant plan changes 2006: ASME published the first edition of B31Q
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13 Implementation Issues
Scope of OQ inspections Evaluation of knowledge, skills and abilities Re-evaluation intervals Maintenance vs. New Construction Treatment of Emergency Response Missing covered tasks (excavation) Extent of documentation Generic vs. task specific Abnormal Operating Conditions Treatment of Training Criteria for small operators Use of directing and observing Noteworthy practices Persons contributing to an accident
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ASME B31Q American Society of Mechanical Engineers (ASME) selected as entity to help develop and house standard ASME B31Q committee selected State and Federal Regulators Operators from all segments of the industry Contractor community Industry Associations Trade Associations Vendors Started August 2003 and published 2006
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ASME B31Q
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Underlying Principles of ASME B31Q
Scope covers tasks that impact the safety or integrity of the pipeline Technically based Prescriptive and Performance options Performance options should have higher expectations on processes Limited number of simple processes for each technical issue with freedom to develop operator’s own methods
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Underlying Principles of ASME B31Q
Clear – should be clear and concise Durable – adequate for multiple cycles Complete – answers all known technical issues Sound – technically sound foundation Use existing rule where practical Not a regulatory document
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Major Aspects of ASME B31Q
Based on holistic approach to address OQ programs in full, not pieces Addresses 12 of PHMSA’s 13 implementation issues Fourteen chapters in B31Q Prescriptive language Performance language (equivalent options for all major requirements) Eight Non-mandatory Appendices Integrated Task List
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B31Q Standard Content Foreword Introduction Definitions References
Qualification Program Determining Covered Tasks Abnormal Operating Conditions Training Evaluation Qualifications Portability Program Effectiveness Communicating the Qualification Program and Managing Changes Documentation Requirements Bibliography
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Non Mandatory Appendices
Appendix 5A – Integrated Task List Appendix 5B – Summary of Integrated Task List Appendix 5C – Task List Development Process Appendix 5D – Evaluation Criteria
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Non Mandatory Appendices
Appendix 6A – Abnormal Operating Conditions (AOCs) Appendix 8A – Evaluation Method Selection Appendix 9A – DIF Analysis for Subsequent Qualification Intervals Appendix 11A – Program Implementation and Effectiveness Appraisals
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ASME B31Q Benefits Standardized task list
Standardized requalification frequencies Identifies key qualification components Allows for portability Rationales are embedded in document Accepted by PHMSA
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Overview of B31Q Committee
Part of B31 Committee History B31Q Project Team B31Q Technical Committee Membership 32 voting member positions About 10 contributing members
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Organization of Committee
Chair Vice-Chair Secretary Teams (Sub-Committees) Team 1: Technical Issues – Task Related Team 2: Technical issues – Non Task Related Team 3: Administrative Membership Diversity Hazardous Liquids - Federal Regulators Gas Transmission - State Regulators Gas Distribution - Contractors Small Operators - Labor Industry/Trade Assoc. - Vendors
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Key Issues Being Addressed
Work-in-progress from 2006 Standard Editorial refinement New tasks Other items
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Work-in-Progress from 2006 Standard
Portability Jobs vs. Tasks Qualification exemptions New construction
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Editorial Refinement Program effectiveness AOC list items
Scope and forward revisions Typographical corrections
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New Covered Tasks Under Consideration
Purging Pigging Operations and maintenance of auxiliary equipment Dehydrators Separators Heaters Coolers
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Other Non Task Related Items Under Consideration
New technology Long-term degradation of physical abilities
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Ways to Participate Comments to secretary Work through members
Attend meetings Upcoming meetings Nashville, October 20-21, 2009 Albuquerque, March 2010 Web site: Search on B31Q Committee
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ANSI Process Technical Committee approval B31 Committee approval
Public comments Publication of approved revisions
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Standards vs. Regulations Keeping Things in Perspective
International standards No jurisdictional bounds Regulators can adopt all or part of a standard
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PHMSA Perspective B31Q addresses the OQ non-compliance issues found to date. PHMSA has publicly stated –” If you meet ASME B31Q, you will meet the regulation.”
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Summary Value of current standard More work to be done
Your participation is welcome Using the standard now and in the future
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Questions
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