National Association of Pipeline Safety Representatives

As part of its efforts in furthering pipeline safety in the United States, NAPSR adopts resolutions to raise serious pipeline safety concerns of national scope to the Pipeline and Hazardous Materials Safety Administration (PHMSA) for consideration in regulatory and enforcement activities.

 NumberDescriptionStatus

CLOSED RESOLUTIONS

2019-1Encourages PHMSA to create a certified web-based or distance learning course designed for excavation contractors and personnel that is specific to pipeline construction excavation and pipeline safety.Closed - Acceptable Response
2013-4 AC 1Urges adoption of suggested language to 49 CFR 191.28 "Reporting Overpressure Events". 
Closed - Unacceptable Response
2010-2-AC2Urges PHMSA to establish regulatory requirements for gas gathering lines in Class 1 locations.Closed - Unacceptable Response
2007-3-AC1Urges PHMSA to amend 49 CFR 191.1 by deleting subparagraph 191.1(b)(4). Many onshore gathering lines are currently exempt from Part 191 reporting requirements; the proposed change would remove that exemption.Closed - Acceptable Response
2016-01Urges PHMSA to modify the requirements regarding State hosted Training SeminarsClosed - Acceptable Response
​​2014-02Encourages PHMSA to require mandatory attendance by all state program managers to the National Association of Pipeline Safety Representatives (NAPSR) National Meetings.​​Closed - Acceptable Response​
2014-01Urges PHMSA to consolidate all databases affecting state program inspection data collection.Closed - Acceptable Response
​​​2013-3-AC1Requests amendment of regulations regarding Operator Identification numbers assigned to pipeline facilities.​​Withdrawn
2013-2-AC1Encourages PHMSA to adopt additional regulations relative to "Farm Taps".​Closed - Acceptable Response
2013-1-AC1Urges PHMSA to incorporate NAPSR concerns and expectations in developing and deploying the Inspection Assistant software application.Closed - Acceptable Response
2012-1-AC1Urges PHMSA to provide funding from appropriated state grant funds for the design, building, operation, and maintenance of an independent NAPSR website.​Closed - Acceptable Response
2011-1-AC1Urges PHMSA to form a task group to analyze and trend dot-reportable incident data for gas distribution.Closed - Acceptable Response
2010-3-AC2Urges PHMSA to develop regulations and policies to address the safe construction and operation of natural gas and hazardous liquids storage field wellbores and geologic formations.Closed - Acceptable Response
2010-1-AC1Urges PHMSA to make available training for personnel who investigate
Damages to natural gas facilities.
Closed - Acceptable Response
​2009-4-AC1Urges PHMSA to improve reporting of plastic material failure data.Closed - Acceptable Response​
​​2009-3-AC1Urges PHMSA to amend 49 CFR 192.325(b) and 192.361 by adding a further requirement for underground clearance between gas mains and service lines and other utility lines.​Closed - Unacceptable Response
​2009-2-AC1Urges PHMSA to improve reporting of plastic material failure data​.Superseded By Resolution 2009-4-AC1
​​2008-3-AC1Urges PHMSA to adopt a more flexible plastic pipe joiner requalification interval.​Closed - Acceptable Response​​
​2008-2-AC1Urges PHMSA to closely scrutinize development of new national consensus standards that may be proposed for adoption by reference or in place of additional rulemaking.​Closed - Acceptable Response​
​2008-1-AC1To allow states access to portions of the federal database necessary to effectively evaluate pipeline operators.Closed - Acceptable Response
​2007-5-AC1Urges PHMSA to update its regulations and instructions to provide operators with consistent and uniform requirements and guidance on the proper mailing address for the submission of written reports. It also asked PHMSA to update the headings in the instructions for the filing of gas distribution system annual reports and gas transmission and gathering systems annual reports.Closed - Acceptable Response
​2007-4-AC1Urges ​PHMSA to amend the definition of Incident in 49 CFR 191.3 to exclude “fire first” events, or in the alternative, if PHMSA believes this data has value, classify “fire-first” incidents in a separate reporting category for events that did not originate on jurisdictional facilities.Closed - Acceptable Response
​2007-2-AC1Urges PHMSA to amend the definition of gathering line and transmission lines in 49 CFR 191.3 and to modify the table in 49 CFR 192.8(b) to deal with pipelines transporting gas containing 100 ppm or more of hydrogen sulfide.Withdrawn
​2007-1-AC1Urges PHMSA to adopt a process for allocating damage prevention grants to state authorities that is the same as or similar to the process it currently uses to allocate One-Call Grants.​Closed - Acceptable Response
​2006-4-AC1Urges ​PHMSA/OPS to begin a process of redeveloping the standards and procedures used in evaluation of state programs, and that this be done in consultation with NAPSR.​Closed - Acceptable Response
2006-3-AC1Urges PHMSA to ​​amend the definition of a Type B gas gathering line to include provisions for leak surveys.​​Closed - Acceptable Response
​2006-2-AC1​Amend the NAPSR Articles of Association to show Arizona moved from the Southwest to the Western Region. This reflects a change in PHMSA’s regional boundaries that is not opposed by the state.​Closed - Acceptable Response
​2006-1-AC1Amend the NAPSR Articles of Association to allow a state to associate with a different region than the PHMSA region, with approval of both regions and the Board.Closed - Acceptable Response
​2005-7-AC1Urges PHMSA that, due to the increasing federal demands on state pipeline safety programs, PHMSA support a law change to allow state grant funding at the 75% level.Closed - Acceptable Response
2005-6-AC1Urges ​that PHMSA not promulgate new regulations that would require the mandatory installation of excess flow valves.Closed - Acceptable Response
2005-5-AC1Urges OPS to amend Subpart G of Part 192 to add standards for service line and meter set installation, requiring repair of damage to new service lines, and adding clearance requirements for separation of service lines from other underground structures.Withdrawn
2005-4-AC1​​Urges OPS to amend 192.614 to require operators to indicate the location where any pipelines have been installed, after the date of the rule change, with less than minimum cover, as part of providing temporary marking.Closed - Acceptable Response
2005-3-AC1OPS intends to make state submissions, reports, and training records available to the public on its website. The resolution requests that OPS make the equivalent information for each of its region offices similarly available to the public.Closed - Acceptable Response
​2005-1-AC1​Requests that PHMSA strongly encourage the National Association of State Fire Marshals to work with NFPA to add standards for the operation and maintenance of underground gas piping to NFPA 54, the National Fuel Gas Code.Closed - Acceptable Response
​BR-4-2 (Priority 1) 2004Requests OPS provide funding for an Administrative Assistant for NAPSR.Closed - Acceptable Response
SR-4-1 (Priority 1) 2004Requests OPS increase the One Call grant funding to $1.5 million, and allow grants to individual states of up to $75,000.Closed - Acceptable Response
​2003-2-ER-P1Due to OQ and IMP workloads, and the sheer numbers of master meter and LP operators, the resolution asks OPS to petition Congress to:
1) Delay the date for determining OQ compliance by small operators by three years until December 17, 2008; and
2) Provide additional financial resources to states for additional inspectors.
​Superseded By Resolution 2005-7-AC1
2003-1-ER-P1Urges OPS to offer invitational travel to the states to accomplish the new training requirements for the new operator qualification and integrity management regulations.​Closed - Acceptable Response
​2002 (No Number Assigned)Requests a congressional review, and requests OPS reconsider, a legal opinion restricting the ability of interstate agent state pipeline safety personnel to travel to other states to conduct or participate in inspections.​Closed - Acceptable Response
​WR-2-02 (2002)​Directs the NAPSR Board to review NAPSR committee charters including their functions, membership, and terms, and report to the Chairman; the Chairman to act based on the report including dissolution or consolidation of committees.​Closed - Acceptable Response
​​CR-1-02 (Priority 1) 2002Urges PHMSA to amend 49 CFR 192.305 to require that contractors who perform construction on natural gas transmission lines and mains not be allowed to self-inspect their own work.​Superseded By Resolution 2015-01
​2001-5-SW-1-01Urges OPS to expand the corrosion control rewrite project for Part 192, including specifically 192.465(e), to re-evaluate the current rules for determining and managing areas of active corrosion.Closed - Acceptable Response
CR-1-01 (Priority 1) (Also listed under 2001-3-CR-1-01)Amends the NAPSR Articles of Association, Article V, Section 3 and creates a new Article 7 to address the filling of National Officer positions that become vacant.Closed - Acceptable Response
​​2001-2-SR-2-01Urges OPS to amend 49 CFR 192.63, “Marking of Material,” to require markings on all pipes, fittings and components last for 50 years or for the life of the pipe, fitting, or component.Closed - Acceptable Response
2001-1-SR-1-01​Encourages OPS to actively seek legislation to require all interstate natural gas, hazardous liquid, and LNG operators to file notification with OPS of all new construction, renewal, or other projects that affect the general public.Closed - Acceptable Response
2000-3-E-NYUrges RSPA to authorize TSI to develop and offer a training course on In-line Inspection Devices.Closed - Acceptable Response
​2000-2-S-NCUrges OPS to define the terms “business district” and “public building” in 49 CFR Part 192.​Withdrawn
2000-1-SW-LA​NAPSR approved creation of a NAPSR Home Page by the NAPSR Electronic Communication Committee (ECC), and requested that RSPA allow the site to be hosted on the OPS web server.Closed - Acceptable Response
​1999-6-CA-P1Urges the US DOT to undertake the necessary rulemaking to support adoption of Standard ASCE 25-97 addressing earthquake-actuated automatic gas shutoff devices into the Title 49 pipeline safety regulations​Withdrawn
1999-4-DE-P1​Urges DOT to defer any rule change allowing the operation of plastic pipe at pressures greater than 100 psig until such time as the ASTM Standard D2513 is amended to address testing of fittings to assure the Department that operation at such pressures will not compromise the use of plastic fittings that utilize o-rings, gaskets, and other designs to seal against leakage; and that the current ASTM D2513 Standard be incorporated by reference including specifically adopting the appendix to the ASTM D2513 Standard addressing the protocol for testing new materials.​Closed - Unacceptable Response
​1999-3-DE-P1​Urges the US DOT to defer any rule change allowing the operation of plastic pipe at pressures greater than 100 psig until such time as assurances are given by plastic pipe manufacturers that the use of CDF backfill material (controlled density backfill containing substances such as cement or fly ash), or other does not jeopardize safe operation of plastic pipe and appurtenances and that the effects of CDF be evaluated as to whether it is an acceptable backfill for use around other materials in gas systems.​Closed - Acceptable Response
1999-2-WI-P1Urges and encourages the RSPA of the US DOT to continue to enable a TSI representative to attend all NAPSR Region meetings.​Closed - Acceptable Response
​1999-1-IA-P1Urges and encourages the RSPA of the US DOT to adopt appropriate standards assuring access by the Secretary and by State pipeline safety agencies to information on pipeline facilities as provided for by Congress in §60102(d).​Closed - Acceptable Response
1998-NAPSR-AGANAPSR joined in a petition by the American Gas Association to OPS to amend 192.123 to increase the allowable operation pressure of certain plastic pipe from 100 to 125 psig.​Closed - Acceptable Response
1998-9-S-TN-P1​Petitions OPS to modify CFR Title 49, Part 192.225(a) to read as follows:

“(a) Welding must be… The quality of the test weld used to qualify procedures shall be determined by destructive testing in accordance with the applicable welding standard(s) contained in Appendix A or other approved industry welding standard(s).” and that “American Welding Society (AWS), B2.1-84 “Standard for Welding Procedures and Procedures Qualifications” be incorporated by reference in Appendix A, Section II.
Closed - Unacceptable Response
​1998-8-S-TN-P1Petitions the OPS to revise CFR Title 49, Part 192.229(c)(1) to read:

”… weld tested and found acceptable under either section 3 or 6 of API Standard 1104, or section 9 of ASME Boiler and Pressure Vessel Code, or section 3 of AWS “Standard(s) for Welding Procedures and Procedures Qualification,” except that a welder qualified under an earlier edition listed in Appendix A of this part may weld but may not requalify under that earlier edition, and petitions the OPS to update Appendix A, Section II to include AWS B2. 1-84 “Standard(s) for Welding Procedures and Procedures Qualifications.”
Closed - Unacceptable Response
​1998-7-S-TN-P1​Urges the US DOT to undertake the necessary studies to support a future rule making to set design, installation, and maintenance criteria for aluminum pipe for the transportation of natural gas and other gases and hazardous liquids; urges the US DOT to encourage the American Society of Testing of Materials, the American Petroleum Institute, and/or the American Society of Mechanical Engineers, and other appropriate industry standard organizations to develop standards for the manufacture, design, installation, and maintenance of aluminum pipe for the transportation of natural gas and other gases and hazardous liquids; urges the US DOT to assign an interim ad hoc committee to study and monitor aluminum pipe installations existing or being installed in the United States and report its findings to the Department.Closed - Unacceptable Response
​1998-6-S-TN-P1Petitions the OPS to revise Appendix C of CFR Title 49, Part 192 to establish limitations(s) on pipe diameter(s) that a welder can weld on in order to be consistent with other approved industry welding standards. Appendix C would read as follows:

Appendix C – Qualification of Welders for Low Stress Level Pipe
I. Basic Test. “…..Cracks that occur on the corner of the specimen during testing are not considered. A welder who successfully passes a butt-weld qualification test under this section shall are qualified to weld on all pipe diameters less than or equal to 12 inches.
Closed - Acceptable Response
​1998-2-E-CN-P1​Petitions the National Chairman of NAPSR to develop a plan for active participation by State regulatory staff on national consensus standards committees.Closed - Acceptable Response
​1997-2-P2Authorizes NAPSR to join with NARUC to conduct a feasibility study of risk management as a regulatory alternative for intrastate pipelines.Closed - Acceptable Response
​1997-1-P1Authorizes the NAPSR Liaison Committee to work with industry representatives and the American Gas Association (AGA) on furthering the various rulemaking proposals initiated by NAPSR as well as other matters of mutual interest.Closed - Acceptable Response
​1996-7-E-WV-P1Implements a means of timely notice to affected states of upcoming interstate pipeline construction projects.​Superseded By Resolution 2001-SR-1-01
​1996-6-W-WI-P1Institutes a procedure to account for unplanned events when computing State grant allocations and incorporate this procedure into the “Guidelines for States Participating in the Pipeline Safety Program” and the annual State evaluation by OPS State Liaisons.Closed - Acceptable Response
1996-5-E-CT-P1Advocates and supports 100% funding for pipeline safety training of state personnel in the Reauthorization process or by some other means.Closed - Unacceptable Response
​1996-4-SW-TX-P1​Provides more timely notice of upcoming public meetings and provide invitational travel for at least one NAPSR representative to attend each workshop.Closed - Acceptable Response
​1996-3-P1​Petitions OPS to update and improve the “Guidance Manual for Operators of Small Gas Systems.”Closed - Acceptable Response
​1996-2-P1​Petitions OPS to limit participation in any risk management trial programs to interstate pipelines operators.Closed - Acceptable Response
1996-1-P1​Petitions OPS to amend 49 CFR Part 192.723(b)(2) to incorporate a 3-month variance window into 5 and 3 year leak survey intervals.Closed - Acceptable Response
​1995-2-E-NH-P2​Asks OPS to work with NAPSR and TSI on the feasibility of a standardized national computer format for the exchange of information among state managers and OPS.Closed - Acceptable Response
​1995-1-C-IA-P2Asks OPS to initiate a rulemaking to adopt proposed definitions of “service line” and “service regulator.” The definitions were designed to address branch services and the status of lines serving meter headers.Closed - Acceptable Response
​1994-2-WY-P1Advises OPS that consideration of environmental concerns should not be at the expense of the human safety factor in the pipeline safety program.Closed - Acceptable Response
​1993-5-P2​Encourages OPS to reduce emphasis on drug and alcohol inspections, which were presented as unduly burdensome and expensive for OPS, states, and industry.​Closed - Acceptable Response
​1993-4-P1The resolution concerns rural oil and gas gathering lines carrying oil and gas containing toxic levels of hydrogen sulfide. The resolution seeks a) Amendment of the Pipeline Safety Acts to make these lines jurisdictional to OPS, b) That OPS determine acceptable design, construction, and monitoring procedures for these lines, 3) That OPS develop a procedure for designating a facility as a Hazardous Facility prior to a catastrophe, and 4) That OPS make appropriate related rule changes.Closed - Unacceptable Response
​1993-3-P1Resolution calls for a) TSI and NACE to form a committee to develop a curriculum and presentation process for corrosion control training, and b) that the committee study the feasibility of having standardized field test facilities in suitable locations throughout the country.Closed - Acceptable Response
​1993-2-P1Resolution a) encourages OPS not to mandate use of excess flow valves on all service lines without developing an industry standard for EFVs, and b)that it should be up to the states to decide if and where EFV installation would be required in that state.Closed - Acceptable Response
​1993-1-P1Resolution calls on the federal government to live up to its commitment to fund the pipeline safety grant program at $9 million.Closed - Unacceptable Response
​1992-4-W-WY-P2Resolution seeks periodic briefings by TSI in each Region on rule changes and technical updates. These briefings would provide continuing education for state inspectors in lieu of taking periodic week-long (and expensive) refresher classes in Oklahoma City.Closed - Acceptable Response
​1992-3-S-TN-P1Resolution seeks guidance from OPS on how states are to comply with 49 CFR Part 198.Closed - Acceptable Response
​1992-2-E-VT-P1Resolution seeks amendment of 49 CFR 199.1 to exempt operators of LP gas systems from the drug testing rules.Closed - Acceptable Response
​1992-1-W-NV-P1Resolution requests that OPS adopt a state staffing formula developed by NAPSR.Closed - Acceptable Response
​1991-3-E-CT-P1Asks OPS to pursue program changes that would provide states with 100% funding for pipeline safety-related training expenses.​Superseded By Resolution 1996-5-E-CN-P2
​1991-2-E-WV-P1​Resolution concerns the practice of wrapping tracer wire around plastic pipe, and the risk of pipe damage if the wire became electrified, such as by lightning. It proposes that OPS issue an alert notice warning of the hazard, and initiate a rulemaking to prohibit the practice.​Closed - Acceptable Response
​1990-7-P2​Petitions OPS to initiate a rulemaking to accommodate use of electrofusion fittings on plastic pipe, including adoption of ASTM F1055.​Closed - Acceptable Response
​1990-6-P1​Proposed a new service line definition that would allow branch services and service lines to multi-meter assemblies.​Superseded By Resolution 1995-1-IA-P2
​1990-5-P1Proposes adding a “residential fuel line” (line from meter or end of service line to building wall) definition to 49 CFR Part192, and requiring that the operator leak survey these lines at intervals not exceeding three years.Closed - Acceptable Response
​1990-3-P1Resolution takes issue with the Operator Qualification rules being proposed at that time. Criticisms included that they gave too much discretion to operators, needed to cover design and construction, and needed specific training procedures.Withdrawn
1990-2-P1​Petitions OPS to change the provisions of 49 CFR Parts 191 and 195 to require operators with facilities in more than one state to file Annual Reports on a state-by-state, rather than combined, basis.​Closed - Acceptable Response
​1990-1-P1​Petitions OPS to initiate a rulemaking clarifying that 49 CFR Part 192 is applicable to customer-owned by-pass/direct sales pipelines.​Closed - Acceptable Response
​1989-2-P1Resolution seeks adoption of additional requirements for the safety of breakout tanks, and immediate adoption of API 650 as an interim regulation.​Closed - Acceptable Response
​1989-1-P1Resolution seeks to amend 192.281(c) to require that saddle fusion joints be made using a mechanical device (no freehand or manual saddle joints).Closed - Unacceptable Response
​1988-1-P1​Seeks removal of the exemption from 49 CFR Part 195 for hazardous liquid pipelines operating at less than 20% of SMYS.Closed - Acceptable Response
​1987-6-P1​Petitions DOT OPS to adopt rules requiring unprotected steel lines be leak surveyed as often as necessary but at intervals not to exceed 3 years.Closed - Acceptable Response
​1986-9-P1​Petitions DOT to initiate an operator personnel qualification rulemaking.Closed - Acceptable Response


RESOLUTIONS