Gas HCA Determinations / Class Location Surveys

On August 6, 2002, RSPA published the final rule for Gas Pipeline High Consequence Areas. The upcoming Gas Pipeline Integrity Management rule will use this definition of high consequence areas to determine what pipelines are required to prepare integrity management plans. This raises a few questions for Gas Pipeline Operators. Is your Class Location Survey up-to-date? Does it reflect the most recent construction and development along your pipeline routes? Can you identify those “Identified Sites” described in new paragraph 761 of Part 192? If your answer to all three questions is not catagorically “Yes”, you have work to do. Note that, unlike the liquid pipeline rule, OPS will not be publishing maps of HCAs for gas pipelines. The operator is responsible for conducting whatever surveys are required. Of course, we can help…. We can perform the Class Location Survey, determine if your pipeline meets the regulatory criteria for operating in its specific Class Location and identify those “Identified Areas” affected by your pipeline’s location.