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

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.

Energy Transfer LP argues that current PHMSA repair criteria and remediation timelines are outdated, overly prescriptive, and impose unnecessary costs on the pipeline industry without providing significant safety benefits.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 They argue that current repair criteria are outdated and prescriptive, and they propose adopting a risk-based approach that leverages modern engineering practices and technologies to reduce unnecessary repairs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.

Marathon Pipe Line LLC supports the proposed repair criteria, specifically advocating for the adoption of API Standard 653 for tank inspections and the incorporation of various API standards for crack and dent management. They argue that these standards provide technically sound, risk-based approaches that improve safety, environmental protection, and operational efficiency.

Colonial Pipeline Company supports the proposed modernization of pipeline repair criteria and remediation timelines, advocating for longer response windows for "near term" conditions based on advances in ILI technology. They argue that these updates, along with specific safety factor adjustments and the adoption of API Standard 653, will enhance safety and operational efficiency while reducing unnecessary excavation costs.

Enterprise Products Operating LLC supports the proposed rulemaking but requests specific modifications to allow for more flexible, engineering-based repair criteria for dents, metal loss, and cracks. They argue that these changes, based on industry standards and their own historical data, will improve cost efficiency and reduce unnecessary excavations and pressure reductions without compromising pipeline safety.

Colonial Pipeline Company supports the proposed modernization of pipeline repair criteria and remediation timelines, advocating for longer "near term" response windows based on advances in ILI technology. They argue that these changes, which include moving toward predicted failure pressure-based criteria and incorporating specific safety factors, will enhance safety while providing significant cost efficiencies and operational flexibility.

ClearPath, a nonprofit organization focused on clean energy and advanced manufacturing, supports PHMSA's efforts to modernize and update repair requirements for hazardous liquid and gas pipelines, specifically highlighting the need for updated CO2 pipeline standards. They argue that modernizing these regulations is essential for supporting the expansion of carbon capture, utilization, and storage (CCUS) infrastructure and ensuring energy security.

The American Petroleum Institute (API) expresses its support for the proposed rulemaking to modernize repair criteria for hazardous liquid and gas transmission pipelines. They argue that current regulations are outdated and do not reflect the scale and complexity of modern pipeline operations, making timely updates essential for safety and efficiency.