GPA comments on EPA's Interim Chemical Accident Prevention Advisory

The Gas Processors Association (GPA) filed comments with the Environmental Protection Agency (EPA) on July 31 in response to an interim advisory stating EPA's concern that some natural gas processing plants that store and process liquefied petroleum gas (LPG) may not be designed in accordance with applicable industry standards and codes (Docket No. EPA 540-F-14-001, Interim Chemical Accident Prevention).  

In January 2014, in response to Executive Order (EO) 13650, EPA published an "Interim Chemical Accident Prevention Advisory: Design of LPG Installations at Natural Gas Processing Plants." In the advisory, EPA requested comments on the specific rulemaking, industry standards, and the hazards they address.

"Our membership possesses a broad and deep technical knowledge of the facilities in question and their operations, so we appointed a multi-discipline ad hoc task force with facility design, safety and environmental expertise to develop the response," said GPA Senior Vice President Johnny Dreyer.

GPA's comments explained that an industry standard alone cannot provide the best practice for every element of design in every situation; engineers and designers require the freedom to choose the best specification and/or standard or the option to develop their own criteria.

"It takes a significant amount of time to revise industry standards, and federal regulation moves even slower. And just because an industry group has published a standard does not mean it is absolutely correct, or up to date, or that everyone agrees with the standard," Dreyer explained. "Engineers need the freedom to exercise their own engineering judgment to make their own informed decisions based on the nature of the facility being designed, the degree of operating risk and their own technical expertise. Most industry standards include language to this effect."

GPA's comments can be summarized as follows:


The Gas Processors Association (GPA) has served the U.S. energy industry since 1921 as an incorporated non-profit trade association. GPA is composed of 130 corporate members that are engaged in the gathering and processing of natural gas into merchantable pipeline gas, commonly referred to in the industry as "midstream activities." Such processing includes the removal of impurities from the raw gas stream produced at the wellhead, as well as the extraction for sale of natural gas liquid products (NGLs) such as ethane, propane, butane and natural gasoline. GPA members account for more than 90 percent of the NGLs produced in the United States from natural gas processing.

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