Re: Petition for Reconsideration of “Pipeline Safety: Periodic Updates of Regulatory References to Technical Standards and Miscellaneous Amendments,” Final Rule, PHMSA-2016-0002 (April 29, 2024)

§ 190.335(a), the Interstate Natural Gas Association of America (INGAA),1 the American Public Gas Association (APGA),2 the American Gas Association (AGA),3 the American Fuel and Petrochemical Manufacturers (AFPM),4 the Liquid Energy Pipeline Association (LEPA),5 and the American Petroleum Institute,6 collectively, the 1 INGAA is comprised of 27 members, representing the vast majority of the U. [...] The incorporation of two separate editions of the same standard is not practicable, reasonable, or in the public interest.10 The Agency provided little support for this decision and the Associations have identified direct conflicts between the regulation and the 2004 edition. [...] The Agency’s decision to proceed with the 2004 edition of ASME B31.8S for two regulations, while incorporating the 2018 edition for the remaining references lacks support in the record and will create unnecessary conflicts and confusion. [...] The Associations also note that PHMSA factored in the time between the Advisory Committee meetings and the publication of the final rule as support for its decision not to grant a longer implementation in the context of a hazardous liquid standard, API RP Std 2350.29 PHMSA made similar arguments in the Leak Detection and Repair Notice of Proposed Rulemaking.30 The Agency’s use of the time between. [...] Conclusion For the foregoing reasons, the Associations respectfully request that the Agency grant the petition, incorporate the 2018 edition of ASME B31.8S for sections 192.714(d)(1) and 192.933(d)(1) and (d)(2)(iv) and set the effective date for the Final Rule to January 1, 2025.