Ten gas gathering industry organizations, including GPA Midstream, joined forces on comments to the U.S. Pipeline and Hazardous Materials Safety Administration calling for substantial changes in leak detection requirements for the industry before the agency finalizes the proposed rule.
PHMSA’s Gas Pipeline Advisory Committee (GPAC) held two meetings, each lasting several days, late last year and this March to review leak detection rules first proposed in May 2023. Those rules included significant changes to reporting requirements and safety standards for gas pipeline facilities.
As we did for comments in October, GPA Midstream jointly responded to PHMSA with the American Petroleum Institute, Independent Petroleum Association of America, Marcellus Shale Coalition, the Petroleum Alliance of Oklahoma and the oil and gas associations of Pennsylvania, West Virginia, Kentucky and Texas. The organizations also presented public comments at GPAC meetings held March 25-27.
While we appreciate the role of the committee in the rulemaking process, it can only do so if PHMSA itself complies with its obligations in the process. PHMSA clearly failed to satisfy those obligations in developing provisions of the proposed rule for gathering lines. The preliminary risk assessment the agency presented to the committee did not meet statutory requirements and proposed regulations for gathering lines that are unreasonable and unsupported.
In our comments, we called on the agency to fix the defects with a revised risk assessment for leaks and create an additional rulemaking proposal that specifically addresses more appropriate standards for leak detection and repair of gas gathering lines.
An earlier PHMSA rule finalized in November 2021, applied new safety standards on more than 90,000 miles of Type C gas gathering lines in Class 1 locations, as well as new reporting requirements on more than 230,000 miles of Type R gas gathering lines. According to PHMSA data last year, more than 500 operators of gas gathering lines are in the process of applying these new requirements.
With its latest set of proposed rules, PHMSA moves the goalposts without proper evidence or considering cost. The agency also fails to address the difficulty of gathering data it would require and sets an unreasonable timeline to meet the new standards.
GPA Midstream also calls on PHMSA to submit a written response to the committee’s report on the March meetings. That report includes significant peer reviewed comments along with concerns of committee members about the adequacy of the agency’s preliminary risk assessment for gas gathering lines. They have until June 25 to submit a written response, as required by the Pipeline Safety Act, and failure to do so would be a clear violation of the statute passed by the U.S. Congress.
