Pipeline Safety: Eliminating Limitations on Welders and Welding Operators

The American Petroleum Institute (API) submits this letter in response to the Pipeline and Hazardous Materials Safety Administration's (PHMSA) request for comments on its "Eliminating Limitations on Welders and Welding Operators" Notice of Proposed Rulemaking (the NPRM). In the NPRM, PHMSA proposes to remove the current limitation on welders of compressor station pipe and components. Section 192.229(a) currently prohibits welders that were qualified through nondestructive testing to weld compressor station pipe and components

The American Petroleum Institute (API), the Liquid Energy Pipeline Association (LEPA), and GPA Midstream Association (GPA Midstream), collectively, the Associations, submit these comments in response to the Pipeline and Hazardous Materials Safety Administration's (PHMSA or the Agency) request for comments on its "Remote Monitoring of Hazardous Liquid Pipeline Rectifiers" Notice of Proposed Rulemaking (the NPRM). In the NPRM, PHMSA proposes to update its Part 195 corrosion control regulations to clarify that operators can conduct rectifier checks remotely as long as the operator also physically inspects each device at least once each year. As PHMSA notes in the NPRM, the Agency's corrosion control enforcement guidance already discusses the use of remote monitoring devices to read rectifiers, bonds, or test stations.