Comment from American Petroleum Institute, Liquid Energy Pipeline Association, GPA Midstream Association
American Petroleum Institute, Liquid Energy Pipeline Association, GPA Midstream AssociationSupportTrade association
Summary: The American Petroleum Institute (API), the Liquid Energy Pipeline Association (LEPA), and GPA Midstream Association support the proposed rule to allow remote monitoring of hazardous liquid pipeline rectifiers. They argue that the proposal provides regulatory certainty, aligns with existing guidance and technology, and reduces unnecessary costs.
The American Petroleum Institute (API), the Liquid Energy Pipeline Association (LEPA), and GPA Midstream Association (GPA Midstream), collectively, the Associations, submit these comments in response to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA or the Agency) request for comments on its “Remote Monitoring of Hazardous Liquid Pipeline Rectifiers” Notice of Proposed Rulemaking (the NPRM). In the NPRM, PHMSA proposes to update its Part 195 corrosion control regulations to clarify that operators can conduct rectifier checks remotely as long as the operator also physically inspects each device at least once each year. As PHMSA notes in the NPRM, the Agency’s corrosion control enforcement guidance already discusses the use of remote monitoring devices to read rectifiers, bonds, or test stations.