The Interstate Natural Gas Association of America (INGAA), which represents the nation’s major interstate gas pipelines, late Friday submitted answers to 120 questions posed by the Pipeline Hazardous Materials and Safety Administration’s (PHMSA) proposed rulemaking on pipeline safety.
PHMSA’s proceeding comes in the wake of the Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011, which was recently signed into law by President Obama. The PHMSA proceeding covers many of the same areas as the law, including integrity management, verification of maximum allowable operating pressures and pipeline safety research/development efforts.
INGAA, whose 27 members operate 200,000 miles of transmission pipeline, urged the federal proceeding to remain focused on identifying the “best ways to enhance and ensure the safety of the nation’s pipelines.” INGAA urged PHMSA to use “performance-based regulation” to foster innovation as opposed to a more “prescriptive” approach that relies on regulatory standards.
As a model, INGAA offered an “Integrated Management Continuous Improvement” (IMCI) approach, which its board outlined last year (see Daily GPI, Sept. 1, 2011). The IMCI action plan has nine steps, which include expanding pipeline risk management work beyond the most highly populated, so-called high consequence areas, expanding and improving corrosion management programs, and improving integrity management communications and transparency.
“As PHMSA develops new regulations, it should consider INGAA’s IMCI action plan as an effective model for assuring pipeline safety through performance-based regulation [or a hybrid] and a limited set of prescribed regulatory standards,” the INGAA filing said.
“Transparency and outreach remain core elements of IMCI implementation,” the filing stated, which outlined an effort last November and December for INGAA members to hold stakeholder feedback sessions. The input from those sessions now will be used to modify the IMCI, an INGAA spokesperson said.
“INGAA and its members are confident that the IMCI action plan provides the right path toward enhancing pipeline safety and assuring public confidence in what already is the country’s safety mode of transporting energy,” the spokesman said.
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