PHMSA Class Location Methodology Workshop Announced

THE DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) published a meeting notice in today’s Federal Register (79 FR 16421-16422) announcing a public workshop looking at whether applying the gas pipeline integrity management (IM) requirements beyond high consequence area would mitigate the need for class location requirements. The workshop will be held on April 16^th, 2014 in Washington, DC.

Background

This workshop is a follow up to a notice of proposed rulemaking (ANPRM) on the subject published on August 25^th, 2011 and a subsequent notice of inquiry published on August 1^st 2013. Public comments from both of those actions will be addressed during this workshop.

This workshop is being conducted as part of the PHMSA response to the integrity management directives found in §5(a)(2) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (PL 112-90).

Agenda

The Draft Agenda for the workshop indicates that there will be five panel presentations. Those presentations include:

• PHMSA – Class locations vs HCA requirements;

• NAPSR perspective on class locations vs HCA requirements;

• Public perspective

• Pipeline operator presentations – Gas transmission; and

• Pipeline operator presentations – Gas distribution and gathering

There will be question and answer sessions after both the morning and afternoon presentations.

Public Participation

PHMSA is soliciting public participation in this workshop. You can attend in person, view the webcast (live or delayed) or you can just submit written comments. You can register for the workshop on-line. Public comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # PHMSA-2013-0161). Those comments must be submitted by May 27^th, 2014.

PHMSA Pipeline Class Location RFI

The Pipeline and Hazardous Material Safety Administration (PHMSA) published a notice in Monday’s Federal Register (available on line Saturday; 78 FR 59906-59907) correcting an earlier publication of an ‘NPRM’ on pipeline class location requirements and extending the comment period on that action.

Last month PHMSA published an ‘NPRM’ on the topic. As I noted in my post on the publication it did not really take the form of a notice of proposed rulemaking in that it didn’t actually pose any specific changes to existing regulations or propose  new regulations. It turns out that it should have been characterized as a ‘notice of inquiry’.

This notice of inquiry is intended to gather information supporting a congressionally mandated {§5 Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (PL 112-90)} report on whether integrity management program (IMP) requirements should be expanded beyond HCAs and whether such expansion would mitigate the need for class location requirements. PHMSA is still looking for responses to the questions outlined in the original notice.

The American Petroleum Institute (API) and American Gas Association (AGA) have requested an extension of the time for submitting comments so that they can get information from their member organizations to fully answer PHMSA’s questions. PHMSA has agreed and the new deadline for submitting comments is November 1sth 2013. Again, public comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # PHMSA-2013-0161).

PHMSA Class Location Requirement NPRM

Today the Pipeline and Hazardous Material Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) in the Federal Register (78 FR 46560-46563) concerning possible revisions to the Class Location Requirements for gas transmission pipelines.

This notice is actually more in the form of an Advance Notice of Proposed Rulemaking (one was already published in 2011 - 76 FR 5308)  since there is no actual proposed language for changes to the Pipeline Safety Regulations. This may explain why the NPRM was not vetted through the OMB before publication. Interestingly, the DOT Unified Agenda suggests that this NPRM will not be published until January, 2014.

As would be expected in an ANPRM PHMSA is requesting public comments on 15 specific questions:

1. Should PHMSA increase the existing class location design factors in densely populated areas where buildings are over four stories?

2. Should class locations be eliminated and a single design factor used if IM requirements are expanded beyond HCAs?

3. Should there only be a single design factor for areas where there are large concentrations of populations, such as schools, hospitals, nursing homes, multiple-story buildings, stadiums, and shopping malls, as opposed to rural areas like deserts and farms where there are fewer people?

4. Should operators be allowed to increase the MAOP of a pipeline from the present MAOP if a single design factor is created for all levels of population density?

5. If class locations are eliminated and a single design factor used, should that single design factor be applied to existing pipelines? There are lots of details added to this question.

6. Should a pipeline that is operated with a single design factor be subject to periodic operational IM measures, similar to the criteria for HCA locations? Again, There are lots of details added to this question.

7. Should pipelines where a single design factor is used for establishing the MAOP be required to ensure that: (see the rule for details of the design factor questions).

8. Should a root cause analysis be required to determine the cause of all in-service and hydrostatic test failures or leaks?

9. Should pipelines without documented and complete material strength, wall thickness and seam records for pipe, fittings, flanges, fabrications, and valves, in accordance with Sections 192.105, 192.107, and 192.109 be allowed to operate at the single design factor?

10. Should operators of pipelines that are allowed to operate at the single design factor complete hydrostatic tests as required by Part 192, Subpart J, and maintain records as required in Section 192.517?Show citation box

11. Should pipelines, under a single design factor, be required to meet additional pipe manufacturing quality controls to minimize defects such as low-strength pipe, steel laminations, and pipe seam defects?

12. Should pipeline construction personnel who would work in areas subject to the single design factor be required to take a construction operator qualification program?

13. For emergency response and pipeline isolation purposes in the event of a rupture or leak, if a single design factor is allowed, what should the maximum spacing be between the mainline valves on a pipeline? There are details added to this question.

14. What should pressure limiting devices be set to for a pipeline operating with a single design factor?

15. If the design factors of class locations were to be eliminated, and a single design factor used instead, what additional design, construction, and operational criteria are required to maintain pipeline safety in urban areas and in rural areas?

Again, public comments are being solicited by PHMSA. Comments may be submitted vial the Federal eRulemaking Portal (www.Regulations.gov; Docket # PHMSA-2013-0161 NOTE: This is a new, separate docket from the earlier ANPRM).  Comments need to be submitted by September 30, 2013.