Lamoni Municipal Utilities - Comments

Re: Proposed Regulation Integrity Management Program for Gas Distribution Pipelines October 15, 2008 Lamoni Municipal Utilities has operated a Municipal owned natural gas system for almost 50 years. Lamoni has 890 customers with a annual load of 120,000 dth . As a small system operator we rely on groups like American Pubic Gas Association ( APGA ) and Iowa Association of Municipal Utilities ( IAMU ). Since we are a small system we can’t afford an engineer on staff. Our membership in APGA and IAMU is like having an engineering firm on staff. These two organizations keep us informed on changing regulations, safety concerns; additionally IAMU performs our OQ training. When ever a new problem arises we are alerted by APGA or IAMU. Concerning integrity management, we don’t have the staff to analyze the reasons why a pipe failed. I don’t intend to hire an engineer to tell me how many pounds of pressure the tooth of the back hoe exerted when it cut the gas main. Nor will I hire an engineer to tell me why a joint failed. Combining our OQ training with good equipment and material, our joints don ‘t fail. These aren’t records that would be of any value to us in operating and maintaining our system. There are already requirements to keep all our inspection and maintenance records. We think PHMSA should keep the current recordkeeping periods for our inspection and maintenance records and not require us to document all the details of how we develop our IM plan. Investor owned facilities already report on thousands of miles of pipe line and hundreds of thousands of services. The investor owned company’s employ hundreds of engineers in mulitiple engineering departments. I gain by their voluntary data submittal. When a problem exists in the gas world, the entire trade knows through alert messages sent out via PHSMA, IPGA, and IAMU to name a few. Many of the new changes are things we already do and submit in another format. In the electrical world, the EIA asks us for data, and the State of Iowa asks us for the exact data, (but in their format). Some times I wonder why government agency’s don’t talk to each other but require. Another concern seems to be redundancy of this proposed rule with other program already in place. The rule would have me develop leak identification and monitoring criteria, our O&M already addresses what has to be monitored and immediately repaired We have an operator qualification program, a drug and alcohol testing program and a damage prevention program. We have not had any accidents caused by our employees so we don’t see any benefit in including in our integrity management plan a section on “Assuring Individual Performance.” That would just be more paperwork. The existing rules are adequate to ensure our workers are qualified. Respectfully Submitted, Emil F. Segebart Jr. General Manager Lamoni Municipal Utilities Lamoni, Iowa