On July 31, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published an
advance notice of proposed rulemaking (ANPRM) asking for public comment on whether they should change its class location requirements for gas transmission pipeline facilities.
The original class location regulations have remained largely intact since PHMSA issued the 1970 final rule. Four class locations are recognized in the current regulations:
• Class 1: A location with 10 or fewer buildings
• Class 2: A location with more than 10 buildings, but fewer than 46
• Class 3: A location with 46 or more buildings, or an area where the pipeline lies within 100 yards of either a building or a small, well-defined outside area (such as a playground, recreation area, outdoor theater, or other such place of public assembly) that is occupied by 20 or more people on at least five days a week for 10 weeks in any 12-month period
• Class 4: A location where buildings with four or more stories above the ground are prevalent.
The class location of a pipeline affects the design and construction requirements and operation and maintenance activities that are required. Class location also determines the design factor when establishing the Maximum Allowable Operating Pressure (MAOP) of the pipeline. An operator must take certain actions to review and confirm the MAOP of a pipeline if it experiences a change in class location due to population growth. These actions, which must be completed within two years of the class location change, may include (1) reducing the MAOP of the affected pipeline segment, (2) replacing the existing pipe, (3) reconfirming the current MAOP based on existing records, or (4) conducting a new pressure test to re-establish the MAOP.
A fifth option is requesting a special permit to maintain the existing MAOP after a class location change has occurred. A special permit is an order waiving an operator’s obligation to comply with a requirement in the pipeline safety laws or regulations. PHMSA only issues a special permit if the operator demonstrates that granting the waiver would not be inconsistent with pipeline safety. Special permits also include additional terms, conditions, and limitations where necessary to maintain safety, protect the environment, or serve the public interest.
The ANPRM asks stakeholders to consider whether actions related to existing or new Integrity Management requirements are sufficient for operating two class locations different than the original design (i.e. operating in a Class 3 location with a Class 1 design factor).
APGA will be working closely with the other industry trade associations (AGA, INGAA, and API) to develop joint industry comments to the questions posed by PHMSA in the ANPRM. Members of the Operations & Safety Committee that operate gas transmission pipelines will be able to contribute and review the comments that are due on October 1, 2018.
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-905-2904 or by email at
ekurilla@apga.org.