Pipeline Safety: Removing Unnecessary Provision for Material Properties Verification during Maximum Allowable Operating Pressure Reconfirmation

Southwest Gas Corporation, a natural gas local distribution company, supports the proposed rule to remove redundant regulatory requirements for material properties verification. They specifically endorse the comments submitted by the American Gas Association to improve clarity in the regulations.

The American Petroleum Institute (API) supports the proposed rule to clarify that operators using pressure test methods for MAOP reconfirmation are only required to test pipe materials cut from test manifold sites if records are unavailable. They argue that the proposal provides necessary regulatory clarity for the natural gas pipeline industry.

The Interstate Natural Gas Association of America (INGAA) and GPA Midstream Association support the proposed rule to clarify and remove unnecessary material properties verification requirements during MAOP reconfirmation. They argue that the change removes ambiguity and eliminates an unnecessary compliance step for pipeline operators.

The American Gas Association and the American Public Gas Association support the proposed rule to remove redundant material properties verification requirements during MAOP reconfirmation. They argue that the current requirements are costly, confusing, and unnecessary because existing failure analysis regulations already ensure adequate safety and material verification.

The Pipeline Safety Trust, a nonprofit watchdog organization, opposes the proposed removal of language requiring material verification for pipe that fails a pressure test. They argue that this specific language is the only explicit link requiring such failures to be investigated under existing safety regulations and suggest conditioning the sentence instead of deleting it.

The National Association of Pipeline Safety Representatives (NAPSR), representing state agency pipeline safety managers, supports the proposed rule to remove unnecessary material properties verification requirements during MAOP reconfirmation. They argue that the change avoids duplicative testing while maintaining safety by still requiring verification when records are untraceable or incomplete.