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AMERICAN%20PETROLEUM%20INSTITUTE%20(API)

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There must be agreement as to the definition of 'gas gathering' so that all ... 1992 U.S. Code Cong. & Admin. News 2642 at 2653 ... – PowerPoint PPT presentation

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Title: AMERICAN%20PETROLEUM%20INSTITUTE%20(API)


1
AMERICAN PETROLEUM INSTITUTE (API) SAFETY
REGULATION OF GAS GATHERING LINES February 5,
2004 - Washington, D.C.
2
Looking ForwardA First Step
  • There must be agreement as to the definition of
    gas gathering so that all parties understand
    what facilities and systems are being considered
    for pipeline safety regulation
  • Industry supports the API RP-80 definitions of
    gas gathering and production operation as a
    solid starting point

3
Looking ForwardA Second Step (Concurrent with
Third Step)
  • Industry, OPS, and NAPSR representatives work to
    fine-tune API RP-80 definitions
  • Preserve intended applications of functional
    definitions of production operations and gas
    gathering systems
  • Limit any potential for abuse of definitions to
    avoid appropriate regulation

4
Looking ForwardA Third Step (Concurrent with
Second Step)
  • Adhere to Congressional Mandate
  • Determine first whether it is necessary to impose
    apply any sort of federal regulation on rural
    gathering lines
  • The Secretary may require owners and operators of
    gathering lines to provide the Secretary
    information pertinent to the Secretary's ability
    to make a determination as to whether and to what
    extent to regulate gathering lines. 49 USCS
    60117(b)

5
Looking ForwardA Third Step (Concurrent with
Second Step)
  • Work with industry work group of company
    representatives and associations
  • Use GPA survey as foundation
  • Possibility of a more extensive survey if needed
  • Evaluate gas gathering incident history as likely
    prediction of future risks
  • Voluntary reporting of gas gathering incidents
  • DOT requirement for reporting of gas gathering
    incidents

6
Looking ForwardA Fourth Step
  • Adhere to Congressional Mandate
  • Recognize
  • A possible outcome of the DOT rulemaking is the
    status quo ante.
  • 1992 U.S. Code Cong. Admin. News 2642 at 2653
  • If federal regulation is warranted for some rural
    gathering lines, limit to appropriate scope given
    actual risks presented

7
Questions to be Evaluated
  • What problems have occurred or are reasonably
    likely to occur as a result of rural gas
    gathering lines not being made subject to federal
    pipeline safety regulations?
  • What operational tools are there to address any
    such problems (aside from applying all pipeline
    safety regulations to currently unregulated
    gathering lines)?
  • Are the benefits from the regulation of
    additional gas gathering lines commensurate with
    the costs of applying such regulation including
    any energy impacts - to the industry, the state,
    and the public?

8
Historical Trends
  • Initial survey results demonstrate very little
    risk associated with rural gathering lines
  • Of gas gathering incidents that have occurred,
    vast majority related to corrosion or 3rd-party
    damage.
  • Evaluate whether there is a need to address these
    incidents with federal regulation and, if so,
    what federal regulation is appropriate?

9
Menu of Pipeline Safety Tools(From Which to
Select As Needed)
  • Corrosion Control
  • Pipeline Marking
  • Continuing public education / public liaison
    efforts
  • Operations and Maintenance Manual
  • Recordkeeping for inspections, monitoring, and
    testing
  • Detailed construction documentation
  • Mapping of systems
  • Pipeline operator qualification standards
  • Risk Assessment / Pipeline Integrity Management
  • Smart pig design

10
New Requirements Cost-Benefit
  • Does the cost of new gas gathering regulatory
    requirements match the benefits of their
    imposition?
  • Will gas gathering incidents be reduced?
  • Will there be greater public awareness of
    pipeline safety issues?
  • Will public safety be measurably improved?

11
Industry Commitment
  • If the data on rural gas gathering safety
    indicates regulatory action is warranted, then
    the industry will step forward once again to work
    in concert with regulators to develop effective
    proposals for addressing the problems identified.

12
API RP 80 April, 2000
THE WAY FORWARD
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