The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), and Interstate Natural Gas Association of America (INGAA) (jointly “the Associations”) submit these comments for consideration by the Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding the gas pipeline provisions of PHMSA’s Notice of Proposed Rulemaking, “Pipeline Safety: Valve Installation and Minimum Rupture Detection Standards” (“Proposed Rule” or “NPRM”).
Pipeline safety is the top priority of the Associations and our members. In general, the Associations support PHMSA’s proposal to require the use of automated valve technology on new gas transmission pipelines and significant replacement projects (note: the Associations use the term “automated valve” to refer broadly to automatic shutoff valves, remote-control valves, and equivalent technology). While pipeline emergencies are rare, operators must be prepared for a quick and safe response. Automated valve technology can be a valuable incident response tool where it is technically and operationally feasible and effectively reduces risk.
Below, the Associations offer detailed comments to assist PHMSA in developing a final rule that enhances pipeline safety, provides clear requirements, and leads to an efficient use of pipeline operators’ resources.
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