Comments to the Pipeline and Hazardous Materials Safety Administration on its Proposed Rule on Safety of Hazardous Liquids Pipelines

Comments to the Pipeline and Hazardous Materials Safety Administration on its Proposed Rule on Safety of Hazardous Liquids Pipelines

The Independent Petroleum Association of America (IPAA) and its members welcome this opportunity to respond to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking referenced above. In particular, that notice proposes (i) the extension of reporting requirements to all gathering lines, (ii) the extension of reporting requirements to all gravity lines moving hazardous liquids, (iii) the inspection of all pipelines in areas affected by extreme weather or natural disasters, (iv) to require periodic integrity testing of pipelines outside of High Consequence Areas (HCAs), (v) to require the use of leak detection systems on hazardous liquid pipelines in all areas, (vi) to add additional conservatism to provisions requiring pipeline repairs as well as requiring repairs on all pipelines even those outside HCAs, and (vii) that all Integrity Management (IM) subject pipelines be capable of supporting inline inspection tools (ILIs) within twenty years, unless the basic construction thereof will not support ILIs.

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