Friday, January 15, 2016
The Gas Processors Association (GPA) has filed comments with the Pipeline and Hazardous Materials Safety Administration (PHMSA) on its proposed rule on the safety of hazardous liquid pipelines. GPA’s comments specifically highlighted that the proposed rule’s $22-million estimated cost is grossly underestimated.
“The actual cost of the proposed rule far exceeds that figure, and it’s important to note that the unaccounted-for costs will be put on midstream operators, and ultimately the end user,” said Matthew Hite, GPA vice president of government affairs. “Moreover, no data or justification has been provided to demonstrate how or why the proposed changes are reasonable or necessary.”
The proposed rule further requires that all lines be piggable. Pipeline pigs are devices that are inserted into and travel throughout the length of a pipeline. They are driven by product flow. “This is a very problematic requirement of the proposed rule,” Hite said. “Requiring systems to be pigged that are physically unable to be pigged is unrealistic. Requiring that the lines be retrofitted is also unrealistic since a majority of the lines do not have minimum flow characteristics to propel the devices through the line.”
GPA also addressed PHMSA’s efforts in regard to high consequence areas (HCAs). GPA is not opposed to changes, but disagrees that the same risks apply everywhere. “We feel that the current definition of an HCA adequately encompasses 99.9% of sensitive areas which pipelines traverse,” added Hite. “We feel this assessment expansion is proposed to cover gathering, which PHMSA has not yet even collected data to determine whether or not there is a problem. This one-size-fits-all expansion is not risk-based and lacks the necessary data to justify it.”
“The actual cost of the proposed rule far exceeds that figure, and it’s important to note that the unaccounted-for costs will be put on midstream operators, and ultimately the end user,” said Matthew Hite, GPA vice president of government affairs. “Moreover, no data or justification has been provided to demonstrate how or why the proposed changes are reasonable or necessary.”
The proposed rule further requires that all lines be piggable. Pipeline pigs are devices that are inserted into and travel throughout the length of a pipeline. They are driven by product flow. “This is a very problematic requirement of the proposed rule,” Hite said. “Requiring systems to be pigged that are physically unable to be pigged is unrealistic. Requiring that the lines be retrofitted is also unrealistic since a majority of the lines do not have minimum flow characteristics to propel the devices through the line.”
GPA also addressed PHMSA’s efforts in regard to high consequence areas (HCAs). GPA is not opposed to changes, but disagrees that the same risks apply everywhere. “We feel that the current definition of an HCA adequately encompasses 99.9% of sensitive areas which pipelines traverse,” added Hite. “We feel this assessment expansion is proposed to cover gathering, which PHMSA has not yet even collected data to determine whether or not there is a problem. This one-size-fits-all expansion is not risk-based and lacks the necessary data to justify it.”
