Underground Construction - January 2019 - 10

WASHINGTONWATCH

Stephen Barlas | Washington Editor

Distribution Pipelines Win Big on New Plastic
Pipe Rules

D

Distribution pipelines will not face
track-and-trace requirements for
newly installed or repaired plastic
pipelines a relief for the American
Gas Association (AGA), which
strongly opposed that potential
mandate when the Pipeline and
Hazardous Materials Safety Administration (PHMSA) first proposed a
series of new standards in 2015.
PHMSA also backed away, either
partly or fully, from some of the
other changes to its pipeline safety
regulations it proposed in 2015,
either because of industry opposition or the advice of its Gas Pipeline
Advisory Committee. The changes
to agency regulations in the plastic
pipe rule published on Nov. 20,
2018, go into effect Jan. 22, 2019.
These changes include
increasing the design factor of
polyethylene pipe, increasing the
maximum pressure and diameter for
Polyamide-11 pipe and components, allowing the use of Polyamide-12 pipe and components, new
standards for risers, more stringent
standards for plastic fittings and
joints, stronger mechanical fitting
requirements, and the qualification
of procedures and personnel for
joining plastic pipe.
Christina Sames, vice president of
operations and engineering at AGA,
says her organization is supportive
of the new rule, although some
of the timelines for compliance
are very short, which will present
challenges. But distribution companies will not have to worry about
new track-and-trace requirements,
which PHMSA wanted to impose in
two years.
"We could have been supportive
of including tracking and traceability
in the final rule if PHMSA would have
allowed enough time to implement,"
Sames said. "An operator's ability to
perform tracking and traceability is
dependent upon process integration

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JANUARY 2019 | UConOnline.com

across multiple company functions,
which can be a long, labor- and
resource-intensive venture."
Bob Biggard, pipeline safety supervisor at the Pennsylvania Public
Utility Commission and the National
Association of Pipeline Safety Representatives (NAPSR) official who
is the lead on Trenchless Plastic
Pipeline Techology, did not respond
to an e-mail asking for comment on
the PHMSA final rule.
One of the more controversial
proposals from 2015 would have
required distribution pipelines to
ensure that the excavation path for
installation and maintenance activities provides sufficient clearance
from other underground utilities
and structures. Additionally, PHMSA
proposed that operators be required
to use a "weak link" device for plastic
pipe through the ground during
installation to prevent unnecessary,
excessive stresses on the pipeline.
NAPSR recommended requiring
operators to pull through an
additional 10 feet beyond the exit
of the ground during trenchless
excavation. If that segment of pipe

showed any damage exceeding 10
percent of wall thickness, NAPSR
suggested that the operator should
be required to replace the installed
segment. NAPSR also recommended requiring the use of a tracer wire,
though it could be installed on an
existing steel pipe if its use on the
plastic pipe is not feasible. PHMSA
declined to mandate any of NAPSR's
suggestions but said it "is open to
enhancing these requirements in
future rulemakings and possibly
hosting a public workshop on weak
links and trenchless excavation."
The mandate to use a weak link
also drew some concern about its
potential limitations, mostly that the
word "device" could limit operators
to commercially available discrete
devices. Some operators commented that they use a piece of weaker
pipe or an internal lab-designed device as a weak link. The commenters
proposed that PHMSA clarify the
language so as not to inadvertently
prohibit alternative technologies.
GPAC voted unanimously to support
these comments. PHMSA revised
the definition of "weak link" to

include a device or method, which
should provide operators more
flexibility.
Several operators had concerns
about the proposed requirement
that operators ensure that the
excavation area is clear of other
underground structures. The GPAC
voted unanimously in favor of
revising the language of this section
to require operators to take "practicable steps" to maintain adequate
clearance from other underground
structures in accordance with "best
practice" documents. In the final
rule, PHMSA uses "practicable steps"
language but omits any reference to
"best practices."
The 2015 proposal around new
"tracking and traceability" requirements didn't go over well with either
distribution pipelines or plastic pipe
manufacturers. These requirements
were also the result of an NAPSR
suggestion stemming from a resolution adopted because of accident
investigations in which insufficient
data regarding pipe material had
proven an obstacle to determining
the cause of an incident.
NAPSR pressed PHMSA to
require the marking of all pipe and
components to ensure identification
for a period of 50 years or the life
of the pipeline. The data required in
the marking would be the six fields
prescribed under ASTM F2897-11a,
including: component manufacturer, manufacturer's lot code, production date, material, type and size.
Industry opposition resulted in
GPAC recommending a phase-in of
the marking provisions by establishing a compliance deadline of one
year for ASTM F2897-11a markings
and a deadline of five years for
record keeping requirements,
instead of PHMSA's proposed "for
the life of the pipeline." GPAC further
recommended that PHMSA limit the
marking and traceability requirements to the categories in ASTM
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