The Interstate Natural Gas Association of America (INGAA), a trade organization that advocates regulatory and legislative positions of importance to the interstate natural gas pipeline industry in North America, welcomes the opportunity to submit additional comments on the Pipeline & Hazardous Materials Safety Administration’s (PHMSA) Integrity Verification Process (IVP).
INGAA members have reviewed PHMSA’s second draft IVP, posted September 11, and agree with many of PHMSA’s changes. INGAA members commend PHMSA for addressing key points made in the public workshop on August 7 and at the Advisory Committee Meeting on August 9. Specifically, INGAA members commend PHMSA for recognizing:
· Maximum Allowable Operating Pressure (MAOP) can be reconfirmed by having a test of material strength to 1.25xMAOP,
· MAOP reconfirmation and Integrity Management (IM) need to be managed as separate processes,
· Records and, in particular, material records are critical for IM,
· Alternate methods need to be developed and approved for determining specified minimum yield strength (SMYS), and
· The benefits of high consequence area (HCA) and moderate consequence area (MCA) designations in lieu of the less accurate class location process.
The comments submitted herein are meant to supplement INGAA’s September 9 filing. In these supplemental comments, INGAA:
1. Provides its own version of an IVP flow chart and a supporting narrative describing the core differences between INGAA’s proposal and PHMSA’s document,
2. Proposes regulatory text at 49 C.F.R. § 192.619(e) to address “grandfathered” pipelines,
3. Clarifies what records are needed for MAOP reconfirmation,
4. Clarifies PHMSA’s early-1970s MAOP confirmation process, including records requirements, and
5. Provides a conceptual view for extending and improving Integrity Management.