Pipeline Safety: Exception for In-Plant Piping Systems

The American Fuel & Petrochemical Manufacturers (AFPM) supports the proposed rulemaking to clarify and codify the regulatory boundaries for in-plant piping systems. They argue that aligning gas in-plant piping with the existing hazardous liquid framework will reduce regulatory overlap with OSHA, eliminate jurisdictional ambiguities, and decrease compliance burdens for operators.

The Williams Companies supports the proposed definition of in-plant piping systems but recommends three specific revisions to clarify jurisdictional boundaries and terminology. They argue that the current language could inadvertently expand PHMSA jurisdiction over equipment already regulated under other standards and propose more precise language regarding "pressure isolation devices" and plant boundaries.

Babst Calland, a law firm, supports the proposed rule to create an in-plant piping exception for gas systems to provide regulatory clarity and reduce burdens. They argue that the rule should clarify that in-plant piping is determined by function rather than ownership and should also include short, low-stress gas transfer lines outside facility grounds.

The Interstate Natural Gas Association of America (INGAA) supports the proposal to codify an exception for in-plant piping systems in natural gas pipelines to reduce regulatory burdens. However, they request specific clarifications regarding jurisdictional boundaries, the definition of "plant," and flexibility for dual-purpose pressure control equipment to avoid duplicative regulations.

The American Petroleum Institute, GPA Midstream Association, and the Interstate Natural Gas Association of America support the proposed rule to codify an in-plant piping exception in Part 192 to provide regulatory clarity and reduce burdens. They request further clarifications to align the gas exception with the existing hazardous liquids framework in Part 195 and advocate for including an exception for short, low-stress transfer lines less than one mile long.

Air Liquide Large Industries US, L.P. supports the rulemaking to delineate in-plant piping limits but requests specific flexibility regarding pressure control devices. They argue that requiring operators to own or operate devices they don't currently control would be costly and propose an alternative where plants can continue operating these devices subject to specific inspection and qualification standards.

Erin Sutherland of the Pipeline Safety Trust, a nonprofit watchdog organization, is requesting a 30-day extension of the comment period for the proposed action. The organization argues that more time is needed to consult with experts and stakeholders to provide comprehensive and substantive feedback.

The Los Angeles Department of Water and Power (LADWP), a municipally owned utility, supports the proposed rule to codify the definition of "in-plant piping system" and exclude such systems from part 192 gas pipeline safety regulations. They argue that this clarification will provide long-term regulatory certainty for their gas-fired electricity generating facilities.

The commenter supports the proposed action and recommends specific wording changes to the definition of "in-plant piping system." They argue that the language should be updated to provide more flexibility regarding the types of control and isolation valves used, particularly when pipeline and plant systems share similar operating pressures.