Based on its interpretations, INGAA offers the following high-level comments on PHMSA’s IVP proposal:
- MAOP verification and IM should not be combined into a single process.
- INGAA fully supports extending and improving IM.
- A single pressure test during a pipeline’s life is an adequate basis for reconfirming an MAOP.
- FFS should be used as the basis for addressing previously untested pipelines and pipelines lacking adequate records.
- INGAA members will work with PHMSA to demonstrate use of ILI in lieu of hydrostatic testing.
- Application of FFS has the desired effect of deleting provisions of the grandfather clause that cause concern to stakeholders.
- PHMSA currently lacks a credible basis for establishing a cost-benefit analysis of IVP.
- Limit the scope of reconfirming MAOP.
Related
Natural Gas & Power Industries’ Reliability Alliance:
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
