Government Regs/Legislation
Guidelines for Parallel Construction of Pipelines PDF
Operator Qualification History and Milestones.pdf
Alternate MAOP FAQs PDF to PHMSA
Summary of Key Operator FAQ’s for the Higher Alternative MAOP Rule
Revised: February 18, 2010
1. How should an operator implement 49 CFR § 192.620(c)(6)?
49 CFR § 192.620(c)(6) provides “If the performance of a construction task associated with implementing alternative MAOP can affect the integrity of the pipeline segment, treat that task as a “covered task”, notwithstanding the definition in § 192.801(b) and implement the requirements of subpart N as appropriate.”
An operator must have and follow a Construction Operator Qualification (COQ) Program for construction tasks that can affect pipeline integrity. The COQ program must comply with 49 CFR § 192.801 and must be followed throughout the construction process for the qualification of individuals performing tasks on an alternative MAOP special permit pipeline.
A construction quality assurance plan (§ 192.328(a)), to ensure quality standards and controls of the pipeline, must be followed throughout the construction phase with respect to the following: pipe inspection (at the last pipe shipping or storage location prior to stringing on the construction right of way, whether rail yard or pipe storage yard), hauling and stringing, field bending, welding, non-destructive examination of girth welds, applying and testing field applied coating, lowering of the pipeline into the ditch, padding and backfilling, and hydrostatic testing. These tasks can affect the integrity of the pipeline segment and must be treated as covered tasks. The individuals driving the pipe stringing trucks to the pipeline ROW would not need to be COQ qualified, unless they are responsible for the pipe unloading.
Other tasks that can affect pipeline integrity which must be treated as covered tasks include, but are not limited to surveying, locating foreign lines, one call notifications, ditching, alternating current (AC) interference surveys and mitigation; cathodic protection (CP) system surveys, mitigation, and installation; conducting directional drills; anomaly evaluations and repairs; right of way clean up (including installation of line markers); and quality assurance monitoring.
Operators are encouraged to review their construction OQ plan with the appropriate PHMSA Regional Director prior to beginning construction.
Revised: 2/05/10
2. Does 49 CFR § 192.620(c)(6) apply only to construction tasks performed after the effective date of the final alternative MAOP rule or does it apply to all construction tasks associated with implementing alternative MAOP, regardless of when the task was performed?
All construction tasks associated with implementing alternative MAOP that occurs after December 22, 2008 (the effective date of the rule) must comply with § 192.620(c)(6). As stated in the preamble to the amendment to the alternative MAOP rule (74 FR 62503), construction activities that occurred prior to December 22, 2008 do not have to comply with 49 CFR § 192.620(c)(6). However, it is important to emphasize that, for existing pipelines, all of the requirements of 49 CFR § 192.112 (including material quality standards) and 49 CFR § 192.328 (including the construction Quality Assurance requirements) apply to construction activities regardless of when they occurred (prior to, on, or after December 22, 2008).
Revised: 2/18/10
3. Are there any special training and qualification requirements associated with the use of higher alternative MAOPs?
49 CFR § 192.620(c)(6) requires operators seeking to operate at the allowable higher operating stress levels to treat construction tasks as if they were covered by subpart N, “Qualification of Pipeline Personnel.” Construction activities are Construction Operator Qualification (OQ) covered tasks regardless of whether or not they meet the four-part test in 49 CFR § 192.801(b). Operators are encouraged to review their construction OQ plan with the appropriate PHMSA Regional Director prior to beginning construction.
Revised: 2/05/10
4. What additional operation and maintenance requirements apply to operation at a higher alternative MAOP?
49 CFR § 192.620(d) sets forth ten operating and maintenance requirements that supplement the existing requirements in Part 192. These include requirements for an operator to evaluate and address the issues associated with operating at higher pressures. Through its public education program, an operator must inform the public of any risks attributable to higher pressure
operations. The additional operating and maintenance requirements address the two main pipeline safety risks, excavation damage and corrosion, through a combination of traditional practices and integrity management. Traditional practices include cathodic protection, control of gas quality, and maintenance of burial depth. Integrity management measures require operators to perform internal inspection on a periodic basis to identify and repair flaws before they can fail.
Revised: 1/19/10
PMSA - OQ Program Modifications.pdf
“Since becoming an operator member with Veriforce, they’ve always been very responsive to our needs, and great at providing innovative solutions to enhance the system. They offer a fresh perspective in dealing with the qualification issues the pipelines have faced and from that have built a solid tool for the operators and contractors.
The service is great, they’re responsive. If you call with a problem it’s generally fixed immediately. There’s not a lot of red tape to go through before they handle things.”
Tim Vaughan, Spectra Energy