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  1. In Memory
  2. PHMSA NPRM Class Location Change Requirements
  3. PHMSA Posts Draft FAQ’s for Midstream Processing Facility Jurisdiction
  4. Oklahoma Underground Gas Storage Regulations
  5. Underwater Inspection Procedures & Inspection Interval Risk Model Updates
  6. RCP’s 2021 Workshop Schedule

PHMSA NPRM Class Location Change Requirements

[Docket No. PHMSA–2017–0151]

On October 14, 2020, PHMSA published a Notice of Proposed Rulemaking (NPRM) to address the requirements for gas transmission pipeline segments that experience a change in class location. 

Public comments are due by December 14, 2020, and may be submitted via the Federal eRulemaking Portal. Include Docket No. PHMSA–2017–0151. 

Under the existing regulations, pipeline segments located in areas where the population density has significantly increased must perform one of the following actions:

  • Reduce the pressure of the pipeline segment,
  • pressure test the pipeline segment to higher standards, or
  • replace the pipeline segment.

This NPRM would add an alternative set of requirements operators could use, based on implementing integrity management principles and pipe eligibility criteria, to manage certain pipeline segments where the class location has changed from a Class 1 location to a Class 3 location. Proposed changes include:

  • Notification to PHMSA within 60 days of a change in class location from class 1 to class 3 if the operator chooses to follow the new alternative to confirm or revise the segment’s MAOP.
  • New definitions for Class 1 to Class 3 location segment, In-Line inspection segment and Predicted failure pressure
  • Added Class 1 to Class 3 location segment to the definition of High Consequence Areas
  • New §618 Class 1 to Class 3 location segment requirements
    • Requirements for adding Class 1 to Class 3 location segments to the operator’s Integrity Management Program
    • Limit what types of pipe are allowed to be classified as Class 1 to Class 3 location segments
    • Integrity assessments must be performed using in-line inspection tools or using alternative assessments or pressure testing following notification to PHMSA under §18.
    • Specifies repair criteria and remediation schedule for Class 1 to Class 3 location segments
    • Additional preventative and mitigative actions for Class 1 to Class 3 location segments
    • Additional remote control or automatic shutoff valve requirements for Class 1 to Class 3 location segments
  • Added dents to §712 Analysis of predicted failure pressure and critical strain level

For a copy of this NPRM, or to discuss how RCP can assist with preparations for the final rule, contact Jessica Foley at jfoley@rcp.com.