Pipeline Safety: Repair Criteria for Hazardous Liquid and Gas Transmission Pipelines

The American Forest & Paper Association and the Process Gas Consumers Group, representing manufacturing trade associations, support the proposed action but request specific modifications to balance safety with economic impacts. They advocate for a minimum safety standard requiring six months of advance notice for pipeline service disruptions, the inclusion of end-user disruption costs in risk assessments, and the issuance of guidance for interactive communication and mitigation plans.

The GPA Midstream Association supports the modernization of pipeline repair criteria regulations to reflect current technologies and analytical techniques. They argue that current regulations require excessive spending on anomalies that pose minimal safety threats and advocate for the adoption of the cost-benefit analysis provided by API and LEPA.

The Interstate Natural Gas of America (INGAA), American Gas Association (AGA), and GPA Midstream Association are submitting supplemental comments to support a performance-based approach to pipeline repair criteria. They argue that current regulations are overly prescriptive and advocate for the use of advanced engineering evaluations, data analytics, and reliability-based cost-benefit analyses to reduce unnecessary excavations and costs.

The American Petroleum Institute (API) and the Liquid Energy Pipeline Association (LEPA) submitted a cost-benefit analysis supporting their proposed revisions to pipeline repair criteria. They argue that modernizing the regulations to allow for risk-based assessments and longer remediation timelines for certain dents and corrosion anomalies will result in over $1 billion in industry cost savings while maintaining safety.

International-Matex Tank Terminals (IMTT), a pipeline and terminal operator, supports the adoption of a risk-based approach for determining inspection intervals for in-service breakout tanks. They also recommend narrowing the definition of "discovery of a condition" to the date a tool vendor delivers a final report to provide a well-defined starting point for remediation timelines.

The Interstate Natural Gas Association of America (INGAA), American Gas Association (AGA), and GPA Midstream Association submit comments supporting the modernization of pipeline repair criteria. They argue for a performance-based approach that allows for the use of advanced technologies and engineering analyses to distinguish between benign manufacturing defects and genuine integrity threats, thereby reducing unnecessary costs while maintaining safety.

Southwest Gas Corporation, a natural gas distribution company, expresses its support for the proposed repair criteria for hazardous liquid and gas transmission pipelines. The company specifically endorses the combined industry comments submitted by the American Gas Association (AGA).

TC Energy Corporation supports the proposed action to modernize pipeline safety regulations, advocating for a shift from rigid, prescriptive requirements to a more flexible, performance-based framework. They argue that incorporating advanced engineering methodologies, such as the Plausible Profiles (Psqr) approach and updated industry standards (e.g., ASME B31G-2023), will improve safety and operational efficiency while reducing unnecessary repair costs.

Energy Transfer LP argues that current PHMSA repair criteria and remediation timelines are outdated, overly prescriptive, and impose unnecessary costs on the pipeline industry without providing significant safety benefits. The company supports PHMSA's review of these regulations and recommends specific amendments to align with modern industry standards, technological advances, and more cost-effective engineering practices.

The American Petroleum Institute, Liquid Energy Pipeline Association, GPA Midstream Association, and American Fuel & Petrochemical Manufacturers are advocating for the modernization of pipeline safety regulations. They argue that current repair criteria are outdated and prescriptive, and they propose adopting a risk-based approach that leverages modern engineering practices and technologies to reduce unnecessary repairs and costs.