In This Issue

Development of Class Location Change Waiver Criteria

OPS has announced the criteria that they will use in considering waiver applications submitted by operators of natural gas pipeline segments that have experienced a change in class location. A class location change results from new construction in the vicinity of a pipeline segment and, in the absence of a waiver, triggers a requirement that the maximum allowable operating pressure be confirmed or revised. The criteria matrix provides information and guidance to pipeline operators concerning the specific pipe design and operating parameters within which OPS is likely to consider a class location waiver application to be consistent with pipeline safety. If granted, a class location waiver would allow a pipeline operator to perform alternative risk control activities based on the principles and requirements of the Integrity Management Program in lieu of pipe replacement or pressure reduction.

Class location waiver requests will be processed through the normal case-by-case waiver approval process. Under 49 U.S.C. 60118, OPS may grant a waiver of any regulatory requirement if granting the waiver is “not inconsistent with pipeline safety.” Therefore, each operator submitting a waiver request has the burden of demonstrating that the proposed waiver would not be inconsistent with pipeline safety with respect to the particular pipe in the affected area. Each waiver request is also subject to public notice and comment.   Operators of intrastate pipelines are required to submit waiver requests at the state level.

Shameless commerce announcement: This is an ideal time to review the class locations of all your gas pipeline systems. The professionals at RCP would be glad to assist you with analysis of your pipeline segments and preparation of any waiver requests that are needed. We can handle your aerial photography, mapping, and engineering analysis needs (yes, we are a professional engineering corporation, in addition to being regulatory experts). Contact Laura Wager for additional information, and for a complete copy of the OPS waiver criteria.