On August 10, APGA submitted comments jointly with the American Gas Association, Interstate Natural Gas Association of America, and the American Petroleum Institute on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Gas Regulatory Reform Rulemaking. This proposed rule is in response to the President’s January 30, 2017, Executive Order (EO) “Reducing Regulation and Controlling Costs” and the two 2017 Department of Transportation requests for public comment on regulations that: are obstacles to transportation infrastructure projects; or, could be repealed, replaced, suspended or modified without compromising safety.
The industry group made seven key recommendations to PHMSA in their comments, outlined below.
- PHMSA should not define the “Service Line” portion of a farm tap in Section 192.740.
- PHMSA should adjust the monetary damage threshold periodically for reporting incidents in Section 191.3.
- PHMSA should clarify the physical inspection interval for remotely monitored rectifier stations.
- PHMSA should clarify the atmospheric corrosion monitoring intervals for gas distribution service lines that have been remediated in Section 192.481.
- PHMSA should clarify its minimum wall thickness requirements for one-inch CTS pipe in Section 192.121.
- The associations support PHMSA’s proposal to align pressure vessel testing requirements with the ASME Boiler and Pressure Vessel Code (BPVC) and recommend modifications to Better Align Part 192 and the ASME BPVC.
- PHMSA should extend the allowance for pre-tested short segments of pipe and fabricated units to pipelines that operate at less than 100 pounds per square inch (psi).
In the fourth recommendation, concerning atmospheric corrosion monitoring intervals, the industry’s comments suggest that PHMSA includes a prescriptive remediation requirement for atmospheric corrosion that allows operators to continue using a five-year inspection cycle.
After PHMSA has reviewed the comments, they will convene a Gas Pipeline Advisory Committee (GPAC) meeting. The GPAC then provides recommendations to PHMSA on the contents of the Final Rule. The GPAC has a tentative meeting scheduled for November 2020 but understands that PHMSA may try to hold the meeting sooner to expedite the finalization of this rule.
For questions on this article, please contact Erin Kurilla of APGA’s staff by phone at (202) 905-2904 or by email at ekurilla@apga.org.