Operator Qualification John Erickson PE American Public Gas

Operator Qualification John Erickson, PE American Public Gas Association

ASME B 31 Q

B 31 Q • Published in 2005 • Non-mandatory national standard • Includes covered task list and abnormal operating conditions for tasks • Covered both gas and liquid pipelines • Covers natural gas distribution • Currently under review for updating

Issues • Include new construction in covered tasks • How does training fit in? When is training necessary?

Training - Examples • • • A covered task not previously performed; Covered task outside knowledge and skills; Qualification suspended or revoked; Fails an evaluation for qualification; New or different knowledge or skills to perform a covered task; • New equipment or procedures

When B 31 Q is revised • Still no plans for PHMSA to incorporate B 31 Q into pipeline safety regulations • B 31 Q does provide a framework for both regulators and regulated to gauge OQ programs

OQ ENFORCEMENT

PHMSA Summary from 2006 • ~ 15% of operators inspected had no OQ program • Several operators were identified that do not address AOCs • Some instances were found where covered tasks were being performed by nonqualified individuals • Some operators failed to verify the qualifications of contractors

Continued • Covered task list missing or incomplete • Knowledge-based, with no evaluation of skills • Omitted reevaluation intervals or failed to support intervals used (many intervals were 3 years for consistency with OSHA training requirements) • Documentation was often insufficient to support demonstration of compliance

Protocol Nine • Inspectors are checking field activities to O&M procedures and OQ evaluations • Are tasks performed as described in the O&M plan and evaluated as in OQ plan? • Georgia cited all systems for noncompliance – fines > $100, 000 • Georgia operators are rewriting their O&M procedures to match OQ requirements

APGA SECURITY AND INTEGRITY FOUNDATION (SIF)

APGA Security and Integrity Foundation (SIF) • Created in 2005 • Funded by PHMSA Cooperative Agreement • Provides programs to assist small systems to operate safely and in compliance – Operator qualification evaluations – Operations and Maintenance procedures – DIMP Model plan

OQ Evaluations • Evaluations in 49 covered tasks (using B 31 Q) • Both written and hands on evaluation • Addresses general and task specific AOCs • Evaluation tools reviewed by an industry/regulator advisory group • Evaluations help close to small operators

Over 1100 evaluated in 13 states

Next program Sept 8 -12 at Leak City

O&M Procedures • Exactly match SIF OQ evaluations • Individual task procedures that can be part of an O&M Plan – List of required tools and supplies – Worker safety issues identified – Step-by-step procedures – Advice for “AOC’s” – Cross references to related task procedures

O&M Procedures • Developed by SIF staff, contractors, MGAG and Austell Gas system • Reviewed by an industry/government panel • Available for free download at www. apgasif. com • New PHMSA extension funds development for remaining B 31 Q distribution tasks

Questions? • jerickson@apga. org • 202 -464 -0834 • www. apga. org