AGA Comments


AGA Comments

AGA Comments from 2014, 2013, and 2012


AGA Comments on PHMSA NOPR: Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes (Sep 9, 2009)

AGA submitted comments on the Notice of Proposed Rulemaking (NPRM) published on July 10, 2015 (80 FR 39916). AGA supports the improvement of pipeline safety through updating existing programs such as Operator Qualification and incorporating modern standards such as API 1104 Appendix B, but noted in our comments several areas of concern. 
Liquid IVP Comments (February 2015)

AGA submitted comments on PHMSA’s draft Hazardous Liquid Pipeline Integrity Verification Process chart. The comments reiterated many of the concerns that were outlined by AGA’s four previous sets of comments submitted on the Gas Transmission Pipeline IVP chart. Those areas include: separation of MAOP verification from expansion of integrity management, delineation of low stress pipelines at 30% SMYS, and the ambiguous introduction of new terms such as moderate consequence areas, engineering critical assessments and spike testing. 
Final Comments on Pipeline Damage Prevention Programs

AGA Final Comments - Notice of Proposed Rulemaking - Pipeline Safety: Pipeline Damage Prevention Programs: AGA final comments submitted to the docket in response to the Pipeline and Hazardous Materials Safety Administration (PHMSA) Notice of Proposed Rulemaking (NPRM), as published in the Federal Register on April 2, 2012.