Introduction The Interstate Natural Gas Association of America (INGAA),1 the American Public Gas Association (APGA),2 the American Gas Association (AGA),3 the American Petroleum Institute (API),4 the GPA Midstream Association (GPA),5 the Liquid Energy Pipeline Association (LEPA),6 and the American Fuel & Petrochemical Manufacturers (AFPM),7 collectively, the Associations, respectfully submit these. [...] Prior to submitting a proposed information collection to OMB for approval, PHMSA must seek comments to “[e]valuate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility.”12 PHMSA must also gather comments to “[e]valuate the accuracy of the agency’s estimate of the burden o. [...] Instead, PHMSA stated that it could meet the intent of the recommendation by “requiring operators to inform PHMSA of the number of valves installed on their system(s) to protect HCAs and class 3 and 4 segments and how they are monitored/operated for emergency closure.”18 In the Notice, PHMSA now seeks to collect the number of miles between RMVs or alternative equivalent technologies, and require o. [...] In addition to assisting the Agency with its response to the NTSB, PHMSA states that it needs the mileage between RMVs to “illustrate the current utilization of the RMVs [and] measure the implementation of the Valve Rule.”30 The Valve Rule went into effect in October of 2022. [...] The Associations agree with the need to take “measured and cautious approach[es], and to account for risks to pipeline integrity, public safety, and environmental protection in the performance of the requirements of part 192.”39 The data will help 37 5 C.
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Table of Contents
- BEFORE THE 1
- UNITED STATES DEPARTMENT OF TRANSPORTATION 1
- PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 1
- WASHINGTON D.C. 1
- COMMENTS IN RESPONSE TO MITIGATION OF RUPTURES AND BLENDING OF 1
- HYDROGEN GAS INFORMATION COLLECTION 1
- FILED BY 1
- INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA 1
- AMERICAN PUBLIC GAS ASSOCIATION 1
- AMERICAN GAS ASSOCIATION 1
- AMERICAN PETROLEUM INSTITUTE 1
- GPA MIDSTREAM ASSOCIATION 1
- LIQUID ENERGY PIPELINE ASSOCIATION 1
- AMERICAN FUEL PETROCHEMICAL MANUFACTURERS 1
- JUNE 24 2024 1
- I. Introduction 2
- II. Detailed Comments 3
- A. PHMSA Should Revise its Proposed Modifications to the Gas Transmission and Gas 3
- Gathering and Hazardous Liquid and Carbon Dioxide Annual Reporting Forms and Instructions. 3
- 1. PHMSAs proposed collection as written is not necessary for the proper 3
- 2. PHMSAs proposed information collection is unnecessary after a Congressionally 5
- 3. The proposed information collection does not currently have a practical utility. 5
- 4. PHMSAs burden estimate is incorrect. 6
- 5. PHMSA does not take into account RCVs or ASVs installed prior to the effective date 7
- 6. Request to PHMSA 7
- B. PHMSA Should Revise its Proposed Collection of Hydrogen Blending Data. 7
- 1. PHMSAs proposal to collect data on discrete hydrogen blend percentages is not 7
- Natural Gas and Hydrogen Gas Natural Gas 9
- 2. Report Form Redline 9
- THIS REPORT PERTAINS TO THE FOLLOWING COMMODITY GROUP 9
- Select Commodity Group based on the predominant gas carried and complete the report for that Commodity Group. File a separate report for each Commodity Group included in this OPID. 9
- WAS HYDROGEN GAS BLENDED WITH REPORTED COMMODITY GROUP DURING REPORTING INTERVAL 10
- FOR BLENDING DURING REPORTING PERIOD 10
- Note 10
- Typical Hydrogen Gas Injected 10
- C. PHMSA should revise the deadline to file an annual report from March to June. 10
- III. Conclusion 11
- Ben Kochman Director of Pipeline Safety Policy Interstate Natural Gas Association of America 25 Massachusetts Ave NW Suite 500N Washington D.C. 20001 bkochmaningaa.org 12
- Alan M. Chichester Senior Director Safety Operations Engineering American Gas Association 400 North Capitol Street NW Washington D.C. 20001 achichesteraga.org 12
- John Stoody Vice President Government Public Relations Liquid Energy Pipeline Association 900 17 Street NW Suite 600 Washington D.C. 20006 jstoodyliquidenergypipelines.org 12
- Erin Kurilla Vice President Operations and Safety American Public Gas Association 201 Massachusetts Ave NE Suite C-4 Washington DC 20002 ekurillaapga.org 12
- Dave Murk Senior Director Pipelines Midstream and Industry Operations American Petroleum Institute 200 Massachusetts Avenue N.W. Suite 1100 Washington D.C. 20001 murkdapi.org 12
- Matthew Hite Senior Vice President of Government Affairs GPA Midstream Association 505 9th Street N.W. Suite 602 Washington D.C. 20004 mhitegpamidstream.org 12
- Rob Benedict Vice President Petrochemicals and Midstream American Fuel Petrochemical Manufacturers 1800 M Street N.W. Suite 900 North Washington D.C. 20036 rbenedictafpm.org 12
