> May 12, 2008 File: OPS
>
> Docket Management System
>
> U.S. Department of Transportation
>
> 1200 New Jersey Avenue, SE
>
> Room W12-140
>
> Washington, DC 20590
>
> **RE: Docket No. PHMSA-2005-23447, Notice 2, Pipeline Safety:
> Standards for Increasing the Maximum Allowable Operating Pressure for
> Gas Transmission Pipelines**
>
> Dear USDOT/PHMSA:
>
> On March 12, 2008, the U.S. Department of Transportation, Pipeline and
> Hazardous Materials Safety Administration (PHMSA), published in the
> Federal Register a Notice of Proposed Rulemaking in the above
> referenced docket.
>
> The rules proposed in this docket would amend 49 CFR Part 192 to allow
> certain pipelines meeting certain conditions to operate at higher
> pressures than would ordinarily be permitted by the current pipeline
> safety regulations for natural gas pipelines. This would be
> accomplished by allowing those pipelines to operate at circumferential
> stress levels which are a higher percentage of the Specified Minimum
> Yield Strength of the steel by changing the Design Factors from 0.72,
> 0.60 and 0.50 to 0.80, 0.67 and 0.56 in Class location 1, 2, and 3
> areas, respectively. With the higher design factors these pipelines
> could qualify for operation at a higher Maximum Allowable Operating
> Pressure (MAOP).
>
> The Iowa Utilities Board (Iowa) is the agency responsible for
> administering the pipeline safety programs of the State of Iowa, and
> for enforcement of the natural gas pipeline safety standards of 49 CFR
> Parts 192, 193 and 199 under certification granted by the U. S.
> Department of Transportation (DOT) pursuant to 49 USC 60105. The Board
> also acts as an interstate agent for interstate natural gas pipelines
> pursuant to 49 USC 60106. The Board therefore has an interest in this
> proceeding and respectfully offers the following comments.

The Board will not dispute statements in the notice that the existing
design factors are of somewhat arbitrary origin and are not based on
metallurgical or other thresholds in the properties of steel. Nor will
it dispute that improvements in the quality of modern steels, pipe
manufacture and pipeline condition assessment technology may have added
a factor of safety not present in older pipelines. It also acknowledges
that pipelines are in service that have safely operated at these higher
stress levels for decades, and that more recently PHMSA has issued a
number of waivers, and is considering others, allowing higher pressure
operation subject to increasingly standardized conditions. But the Board
also agrees that operating at stresses above historically accepted and
proven levels should be accompanied by a higher level of quality and
safety assurance in construction, testing, and operation and
maintenance.

However, as will be discussed below, the Board does believe the proposed
criteria for higher stress operation could be much better organized and
structured.

> **[1. The requirements and eligibility prerequisites for using the
> "alternative maximum allowable operating pressure" would be better
> placed in a separate subpart or in an appendix.]{.underline}**
>
> The rulemaking proposes amending two existing regulations and adding
> three new regulations. Some of the additions are quite voluminous; the
> proposed new § 192.620 alone would add several pages to the pipeline
> safety code.
>
> Although considerable interest in these rules is expected from major
> transmission operators, overall the number of operators able to
> utilize these new standards will be relatively small. The new
> standards would have no relevance to distribution operators or to many
> transmission operators. Adding this much volume of often
> non-applicable regulations will make the code that much harder to
> navigate for other operators generally, plus being intermixed with
> other regulations will make it harder for parties who are interested
> to tweeze out the additional or alternative standards they would need
> to meet.
>
> Iowa believes it would be more effective if the rules for using an
> alternative MAOP were in their own subpart or appendix. The subpart or
> appendix could provide interested operators with a one-stop listing of
> the eligibility requirements and prerequisites for operating at an
> alternative MAOP, followed by sections containing the additional or
> alternative standards such a pipeline would be required to meet.
>
> Further, the rules as proposed are inconsistent with the
> organizational structure of Part 192. As will be discussed more fully
> below, a number of the proposed new provisions are awkwardly or
> inappropriately placed outside of the subparts designated for their
> subject matter. Placing all requirements for an alternative MAOP in a
> separate appendix or subpart would help preserve the integrity of the
> organization and structure of Part 192.
>
> **[2. Items that would be awkwardly or inappropriately placed within
> the code.]{.underline}**
>
> This discussion will identify proposed rule provisions which Iowa
> believes are not well or appropriately located as proposed. Iowa has
> suggested consolidating all alternative MAOP rules into a new subpart
> or appendix, and these comments are intended to support why that is a
> preferable alternative. But if PHMSA elects to retain the currently
> proposed rule structure, these comments will also serve to identify
> areas where rewording or relocation should be considered. The items
> below are examples, and are not intended to represent every instance.

a.  *New 192.112 "Additional design requirements for steel pipe using
    alternative maximum allowable operating pressure."*

> This proposed new rule would be located in Subpart C -- Pipe Design.
> However, the individual requirements listed are generally not design
> standards, but are best described as [pipe or material
> specifications]{.underline}, most of which would be more appropriately
> placed in Appendix B, Qualification of Pipe, or in Subpart B -
> Materials. Specifications for pipe coating, which again are not
> design, are otherwise found in Subpart I -- Requirements for Corrosion
> Control. The criteria proposed in this rule are not Subpart C
> material.

b.  *New 192.328 "Additional construction requirements for steel pipe
    using alternative maximum allowable operating pressure."*

> The items contained in this proposed rule are generally
> [eligibility]{.underline} requirements, not construction requirements,
> and as such would be much better located in rules or a section devoted
> to eligibility for an alternative MAOP.
>
> In addition, this proposed new rule would be added to the Subpart G -
> General Construction Requirements for Transmission Lines and Mains.
> But its content is not "construction" as Part 192 is organized. It
> addresses welding, which is addressed in Subpart E; testing, Subpart
> J; cathodic protection -- Subpart I, and operator qualification --
> Subpart N. Besides lacking construction relevance, placing these items
> as proposed would create subpart conflicts and duplications.

c.  *192.328(a)(2)(ii) and 192.620(c)(5)*

> These two subrules appear to be duplicative requirements for operator
> qualification of persons charged with applying pipe coating. New
> 192.620(c)(5) would in essence apply operator qualification
> requirements to the personnel constructing pipelines intended to
> operate at the alternative MAOP; 192.328(a)(2)(ii) would specifically
> require qualification of coating applicators on such projects. Since
> 192.620(c)(5) would apparently include coating applicators, it is not
> clear why both subrules are needed.
>
> Operator qualification is otherwise covered in Subpart N --
> Qualification of Pipeline Personnel. Rather than introducing new and
> different terms and requirements for qualification of construction
> personnel, it would be simpler and avoid conflict or duplication to
> specify that those persons should be qualified in accordance with
> Subpart N.
>
> **[3. Further Comments and Questions]{.underline}**

a.  *New 192.112(h) Compressor stations*

> The apparent intent of this subrule is to limit the temperature
> experienced by the pipe coating on pipelines being operated at an
> alternative MAOP. The subrule would accomplish this by requiring the
> compressor station upstream of such pipelines be designed with
> limitations on the discharge temperature. But there is a simpler
> solution. An operator need only install heavier wall pipe downstream
> of the compressor and operate it at a conventional MAOP until such
> distance that the temperature is reduced, then go to lighter wall pipe
> operated at an alternative MAOP. The regulation should not exclude
> simpler and perhaps less costly alternatives to compressor station
> redesign.

b.  *192.620(a)(2)(ii) and 192.620(c)(3)*

> These two sections appear both duplicative and conflicting. The first
> subrule would require that for eligible pipelines in Class location 2
> or 3 areas the MAOP would be limited to the test pressure divided by
> 1.50. The second subrule would apparently allow 1.25 times the test
> pressure regardless of class location.
>
> Further, 192.620(c)(3) says the test pressure needs to be at least
> 125% of the MAOP calculated under 192.620(a), which creates a
> circularity with 192.620(c)(3), which has different pressure test
> criteria.
>
> The rule should contain only one provision regarding the test pressure
> used in determining the alternative MAOP.
>
> Also, in Section B.2 of the preamble the American Gas Association
> report referenced[^1] appears to tie higher allowable MAOPs to
> pressure testing above the 90% of SMYS level. This recommendation does
> not appear to be addressed in the proposed rules.

c.  *Proposed subrule 192.620(c)(2)* requires advance notification,
    including provision of certification documents, to PHMSA before an
    operator can begin operating at the alternative MAOP. What if the
    facility is an *intrastate* pipeline? Should not this notice then be
    made to the state? If it is an *interstate* pipeline facility,
    should not affected states also be informed? The final rule needs to
    make provision for the role of states when higher operating
    pressures are proposed.

d.  

e.  *Proposed subrule 192.620(d)* includes a list of additional steps to
    address increased risk. Many of those steps are similar or
    comparable to the integrity management plan requirements of Subpart
    O -- Gas Transmission Pipeline Integrity Management.

> Rather than adding "additional steps" that are comparable to integrity
> management plan requirements, it is suggested PHMSA consider simply
> making pipelines operating at an alternative MAOP subject to Subpart
> O. This would greatly reduce the complexity of the new rules and avoid
> creating yet another set of standards for a subset of pipelines. And
> anticipating that some pipelines that would operate at an alternative
> MAOP would already in whole or in part be subject to Subpart O, the
> burden and confusion of having two sets of regulations covering the
> same pipe segments would be prevented.
>
> If that is not done, is it necessary to adopt as subrules "additional
> steps" that require recalculation of the potential impact circle? It
> should be apparent from Subpart O that the potential impact circle --
> and all other pressure-based components of integrity management --
> must be recomputed if the pressure (or any other calculation factor)
> changes.
>
> *e. 192.620(d)(5)*
>
> Standards for internal corrosion control are already in place in
> 192.475 and 192.476. The rules in 192.476 are not even a year old
> (were effective May 23, 2007). The notice gives no rationale for why
> even more stringent and prescriptive standards should be adopted in
> 192.620(d)(5).
>
> Thank you for the opportunity to comment in this proceeding. If there
> are any questions or a need to contact me concerning these comments,
> feel free to do so at 515-281-5546 (phone), 515-281-5329 (fax), or at
> <don.stursma@iub.state.ia.us>.
>
> Sincerely:
>
> *\[Signed\]*
>
> Donald J. Stursma, P.E.
>
> Manager
>
> Safety and Engineering Section

[^1]: Report No. L30050, "Study of the Feasibility of Basing Natural Gas
    Pipeline Operating Pressure on Hydrostatic Test Pressure." Battelle
    Memorial Institute, 1968.