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Higher MAOP not a wrap
Then, on July 23, INGAA filed a 40 page comment letter with PHMSA supporting the rulemaking in “concept and direction” but suggesting numerous changes. Many of INGAA’s concerns echoed those voiced at the June 10 meeting by Andy Drake, vice president of engineering and construction, Spectra Energy and Jeryl Mohn, senior vice president, operations and engineering, Panhandle Energy. Drake and Mohn said they were generally pleased with the proposed rule. Drake voiced concerns about such things as requirements for temperature limitations for pipeline coatings, whether a requirement for macro etching of pipelines should apply to existing pipelines, and criteria for anomaly repair. In addition, he made it clear that pipelines who have already applied for a Special Permit so as to be able to increase MAOP on a certain pipeline should not have those applications nullified. “I think that would be a huge waste and disruption to the marketplace and this process,” he said.
INGAA’s comment letter also hit hard on that last point. It noted PHMSA has the ability to revoke Special Permits. “All Special Permits granted to date should be grandfathered as a part of this final rulemaking, and all pending Special Permit applications should be considered using prevailing standards rather than the standards that will emerge from this rulemaking,” INGAA emphasized.
But some state regulators are urging PHMSA to resist adopting all of industry’s suggested changes. Donald Stursma, an Iowa Utilities Board regulator, agreed at the June meeting that pipelines should be able to operate at a higher MAOP if that ability is linked to “a higher quality of pipeline material construction and maintenance.” But he complained that PHMSA, in an effort to give the industry everything it wanted, had thrown everything “but the kitchen sink” into the proposed rule. He added, “And I guess I would encourage you not to use criteria of corporations into this rulemaking, whether it has been in a special permit or not, but rather if it can show technical merit to the individual proposals.”