Comments on Pipeline Safety: Gas and Hazardous Liquid Pipeline Risk Models
AGA, API, APGA, INGAA and AOPL jointly submitted comments to PHMSA regarding their risk modeling report. The comments asked that the final report provide a more balanced approach and correctly highlight the strengths, as well as the limitations of each risk modeling method.
- The draft report favors probabilistic models; the Associations recommend that the final report provide a balanced approach in presenting risk modeling methods. Doing so allows operators to identify approaches that best align with their unique systems and helps operators proactively manage risks.
- The final report should identify the strengths and limitations of the different risk modeling methods, as well as provide a more balanced approach for evaluating the risk modeling methods.
- The final report should remove references to specific vendors, and rather guide operators to technologies and systems with further support innovation.
- The final report clarify that the report was authored by PHMSA, and that the recommendations made within the report apply to gas and hazardous liquid transmission pipelines.