1. IMP for Casings October 7, 2009 NACE Eastern Area Conference Max Kieba, PHMSA HQ Engineering and Emergency Support (i.e. Joe Mataich (or other))

2. Codes and Standards Relevant Code Sections include: –§192.921: How is the baseline assessment to be conducted? –§192.925: What are the requirements for using External Corrosion Direct Assessment (ECDA)? –§192.937: What is a continual process of evaluation and assessment to maintain pipeline integrity? –§192.939: What are the required reassessment intervals? Relevant Standards –NACE 0502 (RP-02 currently IBR, soon to be SP-08) “Pipeline External Corrosion Methodology” –NACE 0200 (RP-00 and SP-08) “Steel Cased Pipeline Practices”

3. CASING ASSESSMENT QUALITY ACTION TEAM (CASQAT) Following various correspondence and July 2008 workshop, CASQAT formed to help develop guidelines to further clarify baseline and integrity assessment requirements for cased pipe per 49 CFR 192 Subpart O Goal to develop guidelines that –Help operators determine how to effectively meet December 17, 2012 baseline assessment deadline and beyond –Assist and provide consistency for regulators –Maintain proper balance of being prescriptive enough while also allowing flexibility for engineering judgment –Address any still unresolved statements that start with “But Zach said…” CASQAT met February-June 2009

4. CASQAT Participants (Core-Team) Dave Berger – Cycla/PHMSA Harry Bryant – North Carolina UC (Representing NAPSR) David Chislea – Michigan PSC (Representing NAPSR) Alan Eastman – Mears (Representing Vendors/Service Providers, AGA, and NACE) Bob Fassett – PG&E (Representing AGA, INGAA, and NACE) Mary Holzmann – National Grid (Representing AGA) Max Kieba – PHMSA Engineering (Co-chair/Coordinator) Bill Lowry – PHMSA SW Region Andrew Lu – AGA (Co-chair/Coordinator) Garry Matocha – Spectra (Representing INGAA) Steve Nanney – PHMSA Engineering Victoria Plotkin – AGA Larry Rankin – Corrpro (Representing Vendors/Service Providers) Dane Spillers – Ameren (Representing AGA) Virgil Wallace – Williams (Representing INGAA)

5. CASQAT Cont’d Some main issues being addressed: Acceptable baseline assessment, monitoring, and re-assessment that helps conserve resources while still being consistent with the rule and NACE standards Acceptable criteria for putting casings in regions (by similar type, history, conditions, etc.) Quality fill material and procedures

6. CASQAT Cont’d Other issues being addressed –Conditions to justify “threat of external corrosion has been mitigated” sufficiently to not require full re- assessment –How to address casings filled prior to IM rule Additional info on Cased Crossings, including regulatory drivers, CASQAT minutes, etc: http://primis.phmsa.dot.gov/gasimp/casedcrossing.htm http://primis.phmsa.dot.gov/gasimp/casedcrossing.htm

7. PHMSA Guidelines Next Steps Complete internal review with RDs and Legal – Soon NAPSR review and input Share with others on CASQAT (AGA, INGAA, NACE, etc) – TBD Public release with workshop sometime in November - TBD Finalize guidance ASAP after workshop - TBD