On October 1, APGA joined the Interstate Natural Gas Association of America (INGAA), American Gas Association (AGA), and American Petroleum Institute (API) in joint industry comments on the Advanced Notice of Proposed Rulemaking (ANPRM) on Class Location Change Requirements. This ANPRM requested feedback on the possibility of codifying specific requirements for gas transmission pipelines that were designed to Class 1 requirements but now operate in Class 3 or 4 areas. The following excerpt summarizes industry’s position:
The associations strongly support regulations that advance improvements in pipeline safety practices and that embrace modern integrity assessment processes and technologies, with the intent of achieving a perfect safety and reliability record for our nation’s natural gas pipeline network. The associations commend the Pipeline and Hazardous Materials Safety Administration (PHMSA) for taking steps, through the ANPRM, to update the antiquated regulations governing class location changes for natural gas transmission pipelines. There have been dramatic engineering and technological advances since the class location change regulations were issued in 1970, and the ANPRM represents an important opportunity to promote the continued deployment of modern integrity assessment programs.
PHMSA should modernize its class location regulations by providing an integrity assessment option for managing natural gas transmission pipeline class location changes. Such an approach would leverage modern technologies and processes for evaluating actual pipe condition to confirm the integrity of the class change segment and target any repairs and replacements as appropriate.
It is not necessary for PHMSA to develop brand new, unique integrity management processes for class location changes. The 2016 Proposed Gas Transmission Integrity Rules provide comprehensive requirements that guide how operators employ modern pipeline assessment technologies and processes. These pending regulations have been reviewed by PHMSA’s GPAC over the past two years and enjoy broad support from public, federal, state and industry representatives. Therefore, for class location change segments managed under the integrity assessment option, operators should be required to implement integrity assessment programs in accordance with the 2016 Proposed Gas Transmission Integrity Rules, but on an expedited basis. Furthermore, operators should be required to utilize specific modern internal inspection technologies for assessing class change segments, as detailed in the associations’ comments.
Specifically, an integrity assessment-based option for managing class location changes will:
• Spur further deployment of modern internal inspection technologies;
• Incentivize operators to modify more pipe segments to allow internal inspections;
• Maximize the benefit of the 2016 Proposed Gas Transmission Integrity Rules and encourage early adoption;
• Avoid unnecessary pipe replacements and the associated construction activities, which can cause land disturbances, impact deliveries to consumers, result in releases of natural gas into the atmosphere and needlessly disrupt nearby landowners and communities;
• Promote continuous development of new and improved assessment tools; and
• Reduce the need for PHMSA staff to process individual special permit requests.
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at
ekurilla@apga.org.