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PHMSARulemakingPHMSA-2021-0039

Pipeline Safety: Gas Pipeline Leak Detection and Repair

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Nov 29, 2023
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closed 1077d ago
Interstate Natural Gas Association of America filings
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Activity

Interstate Natural Gas Association of America filed 1 comment on this docket between Aug 17, 2023 and Aug 17, 2023. 65 other organizations filed here. The comment window closed 1077d ago.

What Interstate Natural Gas Association of America filed (1)

Aug 17, 2023· Comment from Interstate Natural Gas Association of America· PHMSA-2021-0039-26287

INGAA supports PHMSA's efforts to prescribe gas pipeline leak detection and repair regulations pursuant to the requirements in Section 113 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020 (the PIPES Act).2 However, INGAA urges the agency to reconsider several of its proposals and reevaluate the costs and benefits associated with the NPRM. Of note, INGAA has provided a detailed analysis of the agency's calculations and conclusions in the Preliminary Regulatory Impact Analysis (PRIA).3 See Exhibit A. INGAA estimates that the costs for gas transmission operators to comply with these new proposals will range between $228 to $516 million annually.4 These cost totals are a stark contrast to PHMSA's assumption of $14.9 million per year. In terms of the benefits associated with the Proposed Rule, PHMSA's cost effectiveness value of the NPRM is $23,763 per metric ton of methane. INGAA performed similar calculations and determined the cost effectiveness ranges between $363,636 to $822,967 per metric ton of methane. Given the significant delta between PHMSA and INGAA figures, the association recommends that PHMSA review INGAA's analysis and recalculate the costs and benefits associated with the NPRM. INGAA supports the Joint Trades' comments and highlights the following modifications that are of particular importance to its members: • Allow a three-year effective date to implement the proposed requirements in the final rule. • Allow flexibility to use different technology and methods fit for purpose to detect and pinpoint leaks. • Accept the Joint Trades' definition of a leak. • Permit transmission operators to use a grade 3 classification for certain leaks and extend the repair timeframes for grade 2 leaks. • Use the date of discovery for determining when an unknown leak started and acknowledge that not all leaks warrant a failure investigation. • Reevaluate whether operators of compressor stations need to comply with the NPRM until the EPA OOOOb and OOOOc rules are finalized. • Determine the need for a recordkeeping provision in section 192.703(d) if the facility is exempted from the Part 192 subpart M requirements. • Set a minimum required patrol frequency of 6 times per calendar year but also allow operators to use a risk-based alternative. • Expand the exception for emergencies to include safety risk and commercial impacts.

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Abstract

Pipeline Safety: Gas Pipeline Leak Detection and Repair

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Co-filers (65)

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