Plastic Pipe Rule NPRM Comments (July 2015)
AGA submitted comments on the Plastic Pipe Rule Notice of Proposed Rulemaking (NPRM). AGA supports many of the proposed changes found within the proposed rule. However, AGA requested that PHMSA remove Tracking & Traceability from the Plastic Pipe Rule. Due to the complexity and potential magnitude that the Tracking & Traceability requirements may have, AGA believes discussions and cost-benefit analyses associated with this topic will inhibit progression of the remainder of the rule. The proposed rule contains many elements of positive impact to the industry and pipeline safety, which AGA would like to see implemented. Within the specific comments AGA outlined areas where further clarification is necessary or provided slight modifications to PHMSA proposals for the thoughtful advancement of pipeline safety. Some of those specific comments included alternative proposals for installations by trenchless excavations, equipment maintenance, backfill requirements and repair criteria for plastic pipe.
|AGA Comment on Plastic Pipe Rule NPRM (July 23, 2015)||212.08 KB|