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Operator Qualification

Operator Qualification

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Operator Qualification

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  1. Operator Qualification John Erickson, PE American Public Gas Association

  2. ASME B31Q

  3. B31Q • 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

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

  5. 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

  6. When B31Q is revised • Still no plans for PHMSA to incorporate B31Q into pipeline safety regulations • B31Q does provide a framework for both regulators and regulated to gauge OQ programs

  7. OQ Enforcement

  8. 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 non-qualified individuals • Some operators failed to verify the qualifications of contractors

  9. 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

  10. 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 non-compliance – fines > $100,000 • Georgia operators are rewriting their O&M procedures to match OQ requirements

  11. APGA Security and Integrity Foundation (SIF)

  12. 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

  13. OQ Evaluations • Evaluations in 49 covered tasks (using B31Q) • 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

  14. Over 1100 evaluated in 13 states

  15. Next program Sept 8-12 at Leak City

  16. 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

  17. 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 B31Q distribution tasks

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