Proposed Revision To Class Location Requirements When Population Increases

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has published an Advanced Notice of Proposed Rulemaking (ANPRM) requesting comments on existing requirements for gas transmission pipelines following population growth. This notice is the result of previous Agency requests for comment, Congressional mandates, Agency workshops, and industry comments dating back nearly a decade. The proposed rulemaking could provide industry with additional options when population increases trigger class location changes, and thereby avoid costly pipe replacement or pressure testing.

'Class location' has long been key to PHMSA gas pipeline safety rules, where a pipeline's safety margins and stringent safety requirements increase as population density increases along the pipeline. The concept originated in industry consensus standards in place prior to minimum federal pipeline safety standards issued in 1970. Class location factors have been incorporated into numerous regulatory requirements (e.g., design, construction, and operations and maintenance including design factors, operating pressures, and block valve spacing). Among other things, the regulations require that operators monitor and update class locations as population changes, which in certain circumstances would require operators to replace, pressure test, or derate transmission pipelines to a lower operating pressure (e.g., 49 C.F.R. Parts 192.5 and 192.611).

Since implementation of the integrity management (IM) rules under 49 C.F.R. Part 192, some in the industry have argued that class locations are no longer necessary, redundant, and/or are overly burdensome and unnecessary in light of improvements in technology and operator IM programs. At the direction of Congress, PHMSA reviewed class locations and found that they should not be eliminated entirely because of the added safety benefits they provide.

Industry groups suggested revisions to the class location rules, particularly in light of PHMSA's proposed rulemaking to extend IM requirements in new areas (moderate consequence areas). One proposal that has found traction in the current deregulatory and regulatory reform environment is the proposal to allow operators alternate methods to substantiate a pipeline's operating pressure in light of an increased class location. This concept is not new, as PHMSA has approved certain alternate integrity assessment and management methods under these circumstances through its Special Permit...