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July 21, 2008

DOT Docket Operations Facility (M-30)

U. S. Department of Transportation

West Building-Room W12-140

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Docket No. PHMSA-RSPA-2004-19854

Integrity Management Program for Gas Distribution Pipelines

Greetings,

I have reviewed the proposed distribution integrity management program
(DIMP), published in the Federal Register on June 25, 2008. I believe it
is a very well thought-out program and should improve the overall
integrity of US gas distribution piping systems. As requested, I am
providing a few comments about this proposed program.

1.  Page 36024 "Section VI. Guidance for IM" states:

"The GPTC will describe the scope and content of the guidance at a
public meeting during the comment period."

I am a member of GPTC and I do not believe that GPTC is planning a DIMP
public meeting during the comment period. We are certainly developing a
DIMP Appendix as part of the GPTC Guide Material.

2\. Page 36026 "Section VIII. Plastic Pipe Issues" states:

"PHMSA believes changes to the PPDC process could significantly improve
operator insight into the risks associated with plastic distribution
pipelines. In particular, more data of better quality and improved
availability of results from PPDC data analysis could help inform
operators of potential integrity issues related to their plastic pipe."

I agree it may be possible to improve upon the information available
from PPDC; however, one must recall that the PPDC process is based on
the voluntary submission of failure data from the gas operators, and in
many cases, this voluntary submission is dependant on gas operator
anonymity.

Also, the failure rate for metal gas distribution piping is about an
order of magnitude, about ten times, the failure rate for plastic gas
distribution piping. PPDC is a well-organized successful method of
collecting plastic pipe failure data to determine if there is a trend in
the failure of a plastic piping material. I believe there should be a
similar program for metal gas distribution pipe failures, especially
since there are so many more failures in metal pipe than in plastic
pipe.

3\. Page 36026 "Section VIII. Plastic Pipe Issues" states:

"PHMSA plans to ask ASTM to revise its current standard for plastic pipe
marking (i.e., ASTM D 2513). PHMSA could then consider incorporating the
standards into federal regulations. PHMSA invites comments on the
desirability of requiring permanent markings on plastic pipe, on the
related technical and logistical issues, and on its proposed approach to
rely on ASTM to establish appropriate standards."

PHMSA currently references an old edition of ASTM D 2513 in their
federal regulation Part 192 -- the 1999 edition. The current 2007b
edition of ASTM D 2513 states:

# 7. Marking {#marking .Section-Title}

7.1  *Pipe*---All required marking shall be legible, visible, and
permanent. To ensure permanence, marking shall be applied so it can only
be removed by physically removing part of the pipe wall. The marking
shall (1) not reduce the wall thickness to less than the minimum value
for the pipe, (2) not have any effect on the long-term strength of the
pipe, and (3) not provide leakage channels when elastomeric gasket
compression fittings are used to make the joints. These marking shall
consist of the word GAS, the designation ASTM D 2513, the
manufacturer\'s name or trademark, the normal pipe size including the
sizing system used (IPS, CTS, or OD), DR or minimum wall thickness,
material designation, and date of manufacture.

As one can see, the current edition of ASTM D 2513-07b already requires
that the markings for plastic pipe shall be permanent. The current
edition of ASTM D 2513-07b also provides methods of assuring permanency
of the marking. All PHMSA has to do is reference this current edition --
ASTM D 2513-07b -- in Part 192 and they will have what they asked for.
ASTM D 2513 has been revised to require permanent marking on plastic
pipe, technical and logistical issues have been addressed as the
manufacturers are already doing this since it is required by ASTM D
2513-07b, and ASTM is definitely the standard that PHMSA should rely on.
PHMSA simply needs to reference this latest edition, ASTM D 2513-07b, in
Part 192 to require permanent marking of plastic pipe.

I hope PHMSA finds these comments useful.

Sincerely,

Dr. Gene Palermo

Palermo Plastics Pipe (P3) Consulting

654 Watershaw Drive

Friendsville, TN 37737

865-995-1156 (Ph)

703-201-8987 (Cell)

865-995-0115 (Fax)

[www.plasticspipe.com](http://www.plasticspipe.com/)

<gpalermo@plasticspipe.com>