[Docket No. PHMSA-2011-0023]
Pipeline and Hazardous Materials Safety Administration (PHMSA) held a public
workshop on April 16th to explore whether applying the integrity management
(IM) requirements beyond high consequence area (HCAs) would mitigate the need
for class location requirements. Locations along gas pipelines are divided into
classes from 1 (rural) to 4 (densely populated) and are based upon the number
of buildings or dwellings for human occupancy. Allowable pipe operating
stresses, as a percentage of specified minimum yield strength (SMYS), decrease
as class location increases from Class 1 to Class 4 locations. Gas IMP
requirements use a different approach to identify areas of higher risk along
The workshop had presentations from PHMSA, State representatives, AGA, INGAA, GPA and APGA and other representatives to review benefits and drawbacks of both methodologies, and the implications of removing class location. AGA noted that operators have been using class location in their policies and procedures successfully since implementation and removing it from code would be complex and disruptive. AGA supports a parallel approach to allow operators to continue using class location, but also allow the use of Integrity Management principles to satisfy class location upgrade requirements in lieu of retesting or replacing operationally functional transmission pipeline that meets safety standards. NAPSR and other State Utility bodies also supported not removing class location since it would affect state code. INGAA recommended a full PIR-based approach, and also a single design factor.
Presentations from the workshop can be found through the link: http://1.usa.gov/1nfT3rP. PHMSA is giving 30 days for comments in Docket No. PHMSA-2011-0023 on www.regulations.gov.