GPA comments on EPA's Interim Chemical Accident Prevention Advisor

The Gas Processors Association (GPA) filed comments with the Environmental Protection Agency (EPA) on July 31 in response to an interim advisory stating EPA's concern that some natural gas processing plants that store and process liquefied petroleum gas (LPG) may not be designed in accordance with applicable industry standards and codes (Docket No. EPA 540-F-14-001, Interim Chemical Accident Prevention).  

In January 2014, in response to Executive Order (EO) 13650, EPA published an "Interim Chemical Accident Prevention Advisory: Design of LPG Installations at Natural Gas Processing Plants." In the advisory, EPA requested comments on the specific rulemaking, industry standards, and the hazards they address.

"Our membership possesses a broad and deep technical knowledge of the facilities in question and their operations, so we appointed a multi-discipline ad hoc task force with facility design, safety and environmental expertise to develop the response," said GPA Senior Vice President Johnny Dreyer.

GPA's comments explained that an industry standard alone cannot provide the best practice for every element of design in every situation; engineers and designers require the freedom to choose the best specification and/or standard or the option to develop their own criteria.

"It takes a significant amount of time to revise industry standards, and federal regulation moves even slower. And just because an industry group has published a standard does not mean it is absolutely correct, or up to date, or that everyone agrees with the standard," Dreyer explained. "Engineers need the freedom to exercise their own engineering judgment to make their own informed decisions based on the nature of the facility being designed, the degree of operating risk and their own technical expertise. Most industry standards include language to this effect."

GPA's comments can be summarized as follows:

  • The most effective way for the federal government to minimize the risk of LPG tank farms and terminals to the public is to sponsor and promote the development of the nation's natural gas liquids (NGL) pipeline network into these new areas under development and help expedite permitting for new large NGL fractionators, and new ethane-consuming chemical facilities such as ethylene plants.
  • GPA is concerned the federal definition of "Recognized and Generally Accepted Good Engineering Practice" (RAGAGEP) will create unintended consequences contrary to the goal of EO 13650 and counsels prudence in that regard.
  • GPA supports EPA's contention that LPG tank farms and terminals represent the type of risk targeted by EO 13650.
  • Gas processing facilities and LPG tank farms and terminals should be considered two different types of facilities.
  • On their own, gas processing facilities do not represent a threat to the public similar to an ammonium sulfate plant or an LPG storage terminal and should not be considered candidates for expanded regulation.
  • Most industry standards listed in the EPA's advisory are not applicable to the design of gas processing facilities and/or LPG tank farms and terminals.
  • Both gas processing facilities and LPG tank farms and terminals are already heavily regulated under existing federal regulations.