Pipeline Safety: Exception for In-Plant Piping Systems

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 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.

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.