INGAA Comments to Pipeline Safety: Workshop on Anomaly Assessment and Repair

INGAA would like to file the following information to docket PHMSA–2008–0255 in order to clarify the INGAA position discussed in the previously filed document.  There has been Corrective Action Orders (CAO) published recently (Columbia Gas 420071017H and Transco 120081004H  ) that addressed the evaluation, response, repair and mitigation of anomalies found during in-line inspection. In addition PHMSA has proposed and finalized criteria in the rulemaking titled "Pipeline Safety: Standards for Increasing the Maximum Allowable Operating Pressure for Gas Transmission Pipelines".  INGAA is concerned that these positions by PHMSA vary from accepted consensus standards and practices of the natural gas transmission pipeline industry.