On March 15, APGA joined industry coalition comments from the American Petroleum Institute (API), American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA) on the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed rule Periodic Updates of Regulatory References to Technical Standards and Miscellaneous Amendments.
The comments highlighted the following eight points.
1. PHMSA should update regulatory references to technical standards at least biennially. By establishing an expectation that these rulemakings occur biennially, the consensus standards making groups and the industry can better anticipate changes in regulatory requirements. More frequent updates from PHMSA will ensure that the latest technical standards are incorporated by reference, which will result in more up-to-date pipeline safety regulations.
2. PHMSA should clarify the requirements for cathodic protection on double-bottom breakout tanks by referencing ANSI/API RP 651, which precludes the use of cathodic protection.
3. PHMSA should consider incorporating by reference the second edition of API RP 80: “Guidelines for the Definition of Onshore Gas Gathering Lines,” currently referenced in 49 C.F.R. 192.7(b)(4).
4. PHMSA should consider incorporating by reference API RP 1181: “Pipeline Operational Status Determination,” to implement Section 109 of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020.
5. PHMSA should continue to allow operators to install pipe that is compliant with the 45th Edition of API 5L and flanges that are compliant with the 2010 Edition of MSS SP-44 until January 1, 2022.
6. 49 C.F.R. § 195.3(b)(7) incorrectly references a non-existent edition of API RP 1130 and should be amended.
7. PHMSA should incorporate the 2018 edition of ASME B31.8S.
8. PHMSA should clarify that a flange or flange accessory that meets the minimum requirements of ASME/ANSI B 16.5 or MSS SP-44, is in compliance with 49 C.F.R. § 192.147(a).
PHMSA will now schedule a Gas Pipeline Advisory Committee (GPAC) meeting to discuss this rule and the comments received. Once the GPAC provides its input, the rule can be finalized.
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at
ekurilla@apga.org.