{"operation":"document","citation":"0900006482028f72","title":"U.S. DOT/PHMSA - Report to Congress - Evaluation of Expanding Pipeline Integrity Management Beyond High-Consequence Areas and Whether Such Expansion Would Mitigate the Need for Gas Pipeline Class Location Requirements - Pipeline Safety, Regulatory Certainty, And Job Creation Act 2011, Section 5","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"Report to Congress Evaluation of Expanding Pipeline Integrity Management Beyond High-Consequence Areas and Whether Such Expansion Would Mitigate the Need for Gas Pipeline Class Location Requirements Pipeline Safety, Regulatory Certainty, And Job Creation Act 2011, Section 5 April 2016 Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration U. S.... Table of Contents Executive Summary ...................................................................................................................................... ii 1. INTRODUCTION ................................................................................................................................ 1...","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006482028f72.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006482028f72.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006482028f72","source_url":"https://downloads.regulations.gov/PHMSA-2011-0023-0153/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nReport to Congress\nEvaluation of Expanding Pipeline Integrity\nManagement Beyond High-Consequence Areas and\nWhether Such Expansion Would Mitigate the\nNeed for Gas Pipeline Class Location Requirements\nPipeline Safety, Regulatory Certainty,\nAnd Job Creation Act 2011, Section 5\nApril 2016\nOffice of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nU. S. Department of Transportation\n\n<<<PAGE 2>>>\n\nTable of Contents\nExecutive Summary ...................................................................................................................................... ii\n1. INTRODUCTION ................................................................................................................................ 1\n2. EXPANSION OF IM REQUIREMENTS BEYOND HCAs (The Act § 5(a)(1)) ................................ 1\n2.1 History of IM Program .................................................................................................................. 1\n2.1.1 History of Hazardous Liquid IM Program............................................................................ 1\n2.1.2 History of Gas Transmission Integrity Management Program ............................................. 2\n2.2 ANPRM: Safety of Hazardous Liquid Transmission Pipelines .................................................... 4\n2.3 ANPRM: Safety of Gas Transmission Pipelines .......................................................................... 4\n2.4 Expanding IM Requirements to Areas Outside HCAs ................................................................. 6\n2.4.1 Hazardous Liquid ......................................................................................................................... 6\n2.4.2 Gas Transmission ......................................................................................................................... 7\n2.4.3 Notice of Proposed Rulemaking ................................................................................................. 10\n3. DOES EXPANSION OF IM BEYOND HCAs MITIGATE THE NEED FOR CLASS\nLOCATIONS? (The Act § 5(a)(2)) ............................................................................................................ 11\n3.1 Class Locations (Background) .................................................................................................... 11\n3.1.1 History of Class Locations .................................................................................................. 11\n3.1.2 Purpose of Class Locations ................................................................................................. 14\n3.2 ANPRM: Safety of Gas Transmission Pipelines ........................................................................ 22\n3.3 Notice of Inquiry: Class Location Requirements ........................................................................ 24\n3.3.1 History leading up to Request for Comments on Class Location Regulations ................... 24\n3.3.2 Summary of Comments Received on Need for Modifying Class Locations ........................ 24\n3.4 Pipeline Advisory Committee Meeting ....................................................................................... 25\n3.5 Class Location Workshop ........................................................................................................... 27\n3.6 Class Location Approach versus IMP Approach ........................................................................ 34\n3.7. Alternatives to Class Locations ................................................................................................... 38\n3.7.1 Single Design Factor .......................................................................................................... 38\n3.7.2 Sliding Mile Based upon Potential Impact Radius ............................................................. 38\n3.7.3 Expand Class Locations ...................................................................................................... 42\n3.7.4 Bifurcated Approach ........................................................................................................... 42\n3.7.5 Revise §192.611 to Include Additional IM Oriented Methods for Addressing Class\nLocation Changes ............................................................................................................................... 42\n3.7.6 No Change in Class Location Methodology ....................................................................... 42\n4. CONCLUSION ................................................................................................................................... 43\n5. FUTURE CONSIDERATION OF CLASS LOCATION ................................................................... 43\nAppendix A - Abbreviations ..................................................................................................................... A-1\nAppendix B – Class Location Waiver Criteria ......................................................................................... B-1\nDepartment of Transportation i Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 3>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\nExecutive Summary\nSection 5(c) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (the Act)\n(Pub. L. 112-90) requires the Secretary of Transportation to “evaluate (1) whether integrity\nmanagement (IM) system requirements, or elements thereof, should be expanded beyond high\nconsequence areas (HCAs); and (2) with respect to gas transmission pipeline facilities, whether\napplying IM program requirements, or elements thereof, to additional areas would mitigate the\nneed for class location requirements.” Section 5(f) of the Act authorized the Pipeline and\nHazardous Materials Safety Administration (PHMSA) to issue regulations in accordance with\nthe report after the conclusion of a review period. This report documents that evaluation and\naddresses whether IM program requirements should be expanded beyond high consequence areas\n(HCAs) and, specifically for gas transmission pipelines regulated under 49 Code of Federal\nRegulations (CFR) Part 192, whether such expansion would mitigate the need for class location\ndesignations and corresponding requirements. PHMSA conducted a class location public\nmeeting on April 16, 2014, and requested public comments to be submitted to Docket Number\nPHMSA-2013-01611 located on the internet at regulations.gov. Public comments received on\nthe docket were evaluated.\nIn October 2010 and August 2011, PHMSA published notices in the Federal Register to solicit\ncomments on revising the pipeline safety regulations applicable to hazardous liquid and natural\ngas transmission pipelines including expansion of IM program requirements beyond HCAs. In\ngeneral, industry representatives and pipeline operators were opposed to any expansion of HCAs\nand in favor of eliminating class locations on newly constructed pipelines, whereas public\ninterest groups were in favor of expanding HCAs but against curtailing class location\nrequirements.\nPHMSA has carefully considered the input and comments. At this time, PHMSA plans to\npropose an approach that balances the need to provide additional protections for persons within\nthe potential impact radius (PIR) of a pipeline rupture (outside of a defined HCA), and the need\nto prudently apply IM resources in a fashion that continues to emphasize the risk priority of\nHCAs. PHMSA, therefore, is considering an approach that would require selected aspects of IM\nprograms (namely, integrity assessments and repair criteria) to be applicable for non-HCA\nsegments. For hazardous liquid pipelines, PHMSA would propose to apply these requirements\nfor non-HCA pipeline segments.\n2 For gas transmission pipelines, PHMSA would propose to\napply these requirements where persons live and work and could reasonably be expected to be\nlocated within a pipeline PIR. Under this approach, PHMSA would propose requirements that\n1 On August 25, 2011, (76 FR 53086) PHMSA published in the Federal Register an Advance Notice of Proposed\nRulemaking (ANPRM) titled: “Safety of Gas Transmission Pipelines” seeking comments on the need for changes\nto the regulations covering gas transmission pipelines. Public comments from this ANPRM are posted on Docket\nNumber PHMSA-2011-0023 located on the internet at regulations.gov.\n2 Gas and Hazardous Liquid (HL) Notices of Proposed Rulemaking (NPRM) both protect the safety of humans in a\nsimilar manner. The difference is the environmental effects of HL versus gas releases on the environment\nincluding the effects on soils, streams, and rivers. Due to gas being lighter than air, gas rises up and does not\npollute soil, streams, and rivers compared to hazardous liquids such as crude oil which is heavier than air.\nDepartment of Transportation ii Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 4>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\nintegrity assessments be conducted, and that injurious anomalies and defects be repaired in a\ntimely manner, using similar standards in place for HCAs. However, the other program elements\nof a full IM program contained in 49 CFR Part 192, Subpart O, or 49 CFR Section 195.452 (as\napplicable) would not be required for non-HCA segments.\nThe Act also required the Secretary of Transportation to evaluate if expanding IM outside of\nHCAs for gas transmission pipelines, as discussed above, would mitigate the need for class\nlocation requirements.\nExpanding IM Requirements Beyond HCAs\nBased upon findings from lessons learned, accident investigations, assessments, IM, and\noperations and maintenance (O&M) considerations, PHMSA is proposing through a notice of\nproposed rulemaking (NPRM) to apply selected IM program elements (i.e. assessments and\nremediation on a continuing interval) to areas outside HCAs. For gas transmission pipelines, the\nassessment and remediation requirements would be limited to selected areas outside HCAs\nidentified in this report as moderate consequence areas (MCAs). This integrity assessment\napproach for non-HCA locations is addressed in separate NPRMs for both gas transmission and\nhazardous liquid pipelines.\nClass Location\nOn August 1, 2013, PHMSA published a notice in the Federal Register (78 FR 46560) soliciting\ncomments on expanding gas IM program requirements and mitigating class location\nrequirements (Class Location Notice). Comments in the Class Location Notice were solicited on\nwhether:\n1. PHMSA should increase the existing class location design factors in densely populated\nareas with building over four stories?\n2. Class locations should be eliminated and a single design factor used, if IMP requirements\nare expanded beyond HCAs?\n3. Should there be only a single design factor for pipeline areas where there are large\nconcentrations of populations along the pipeline; such as schools, hospitals, nursing\nhomes, multiple-story buildings, stadiums, and shopping malls, as opposed to rural areas\nlike deserts and farms where there are fewer people?\nA class location workshop was held on April 16, 2014, to discuss this notice and comments were\nreceived from stakeholders, including industry representatives, pipeline operators, state\nregulatory agencies, and the public. Based on PHMSA’s evaluation of written comments and\nstakeholder input at the workshop, PHMSA considered several alternatives for changing the\ncurrent regulations with respect to defining class locations and how to approach changes in class\nlocation, when they occur, which include:\nSingle Design Factor\nPHMSA solicited comments on the use of a single design factor for all pipeline class locations as\nan alternative to the current method for determining class locations. The proposal was to use a\nDepartment of Transportation iii Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 5>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\nhigher design factor where there are large concentrations of populations, such as schools,\nhospitals, nursing homes, multiple-story buildings, stadiums, and shopping malls.\nThe comments on the use of a single design factor were overwhelmingly negative. Commenters\nfelt that, to mitigate class locations by going to a single design factor approach would impact too\nmany of the existing requirements in 49 CFR Part 192, including design, construction, and\noperational inspections and would be complicated to implement and may result in a decrease in\nsafety in populated areas.\nSliding Mile Based upon Potential Impact Radius\nThe current sliding mile methodology for determining a class location unit could be replaced by\na methodology based on the HCA PIR. Some pipeline industry comments suggested this\napproach may have merit for new and replaced pipe instead of existing pipe. An additional\nsafety factor would be considered if this method were proposed. One operator proposed a\nmethod similar to the PIR approach. The operator called it “the Class Location Circle”\napproach. The Class Location Circle would be either 300 feet in radius or the PIR of the pipeline\nwhichever results in a larger area. Also, another operator proposed a redefinition of the class\nlocation densities over those currently found in 49 CFR Section 192.5.\nExpand Class Locations\nGas transmission pipelines are currently classified as Class 1, 2, 3, or 4 locations. A Class 4\nlocation is defined as a class location where buildings of four (4) or more stories are prevalent.\nHeavily developed urban areas have many buildings over four stories high. While some\ncommenters felt that the existing class location approach should be retained and expanded to\ninclude additional class locations for densely populated urban areas with buildings over four\nstories tall, a majority of industry and operator commenters were against adding additional class\nlocations. The industry representatives and pipeline operators felt that new class locations with\ndesign factors lower than the current 0.4 design factor for Class 4 locations would make it\ndifficult to continue to supply natural gas to the newly classified areas.\nBifurcated Approach\nThe Interstate Natural Gas Association of America (INGAA) submitted a written request to keep\nthe current method for existing pipelines, but add a new method using the PIR approach for new\nconstruction and replaced pipelines. This approach would utilize the HCA PIR type approach\nfor new or replaced pipelines only and would keep the current class location definitions and\napplications for existing pipelines.\nINGAA’s bifurcated approach would allow class location changes to existing pipe including pre-\nCode pipe with additional operational and integrity measures, and new pipelines with a single\ndesign factor in all class locations to have additional material, construction and integrity\nmeasures.\nClass Location Changes – Allow Additional IM Assessments\nOne alternative being considered is to retain the current method for determining class locations\nbut to revise the regulations for addressing changes in class locations. Such changes might\nDepartment of Transportation iv Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 6>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\ninclude alternatives in addition to pipe replacement, retesting, or de-rating, such as incorporation\nof IM practices to validate the condition of the pipe and monitor the pipe within an IM process.\nSpecifically, the INGAA suggested that PHMSA consider and engage stakeholders regarding\neighteen categories of standards or requirements that could be developed through rulemaking to\nreplace the current Class Location Special Permits program. The eighteen categories suggested\nby INGAA are similar to the conditions PHMSA has used in granting class location special\npermits. Such an approach would provide regulatory certainty.\nNo Change\nRetain the current 49 CFR Part 192 methods for determining class location (definition) and class\nlocation changes along with the requirements that correspond with those designations, including\nMaximum Allowable Operating Pressure (MAOP), pressure testing, operational inspections and\ninspection intervals.\nConclusion\nOverall, the majority of stakeholder responses suggested that PHMSA not change the current\nclass location approach for class locations and class location changes as population increases\nused for establishing MAOP and O&M surveys for existing pipelines. For new transmission\npipelines, some industry groups and operators supported some type of bifurcated approach for\nexisting and new pipelines as described above. Other commenters suggested alternatives to\nrequirements that sometimes result in pipe replacement when class location changes.\nFor gas transmission pipelines, PHMSA believes the application of IM assessment and\nremediation requirements to MCAs does not warrant elimination of class locations. Class\nlocations affect all gas pipelines, including transmission (interstate and intrastate), gathering, and\ndistribution pipelines, whether they are constructed of steel pipe or plastic pipe. Class location is\nintegral to determining MAOPs, design pressures, pipeline repairs, HCAs, and O&M inspections\nand surveillance intervals.\n3 Class locations affect 12 subparts and 28 sections of 49 CFR Part\n192 for gas pipelines. The subparts and sections are listed and discussed in Sections 3.1.2.4 and\n3.7.2.2. While assessment and remediation of defects on gas transmission pipelines is an\nimportant risk mitigation program, it does not adequately compensate for other aspects of class\nlocation as it relates to other types of gas pipelines and as it relates (for all gas pipelines) to the\noriginal pipeline design and construction such as the design factor, initial pressure testing,\nestablishment of MAOP, O&M activities, and other aspects of pipeline safety, that are based on\nclass location. Also, there are some disadvantages to using only the PIR circle method without\ninclusion of class locations that use human dwelling counts or buildings within the PIR. For\ninstance: (a) PIR approach may exclude buildings/homes for PIRs less than 660 feet, which\ncould be impacted from a pipeline rupture and are now included in the class location unit, (b)\nPIR approach does not take into account pipe wall thickness, grade, seam type, testing history, or\n3 PIR could be used as an alternative to the class location spacing unit (§ 192.5(a)(1)) of 220 yards (660 feet) on\neither side of the pipeline used to determine class locations for new pipelines. The class location dwelling count\nwould need to have similar numbers as defined in § 192.5 for either the current class location unit or a “PIR\nbased” class location unit. In this way, the PIR approach could be used to define class locations in order to\nconstruct risk/design factor categories.\nDepartment of Transportation v Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 7>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\ndesign factor, and (c) it may not take into consideration future development adjacent to PIR\ncircle without requirements for future surveys. Thus, PHMSA has preliminarily determined to\nnot eliminate the existing class location requirements. 4\nFuture PHMSA Consideration of Class Location\nPHMSA acknowledges that, although it has decided to not eliminate class location requirements\nat this time, industry raised some legitimate issues with the existing rules, or lack thereof, for\nimplementing class location. PHMSA will continue to listen to stakeholder input and consider:\n• Comments and suggested approaches submitted on the docket in response to this report;\nDocket Nos. PHMSA-2011-0023, PHMSA -2013-0161 and the April 16, 2014 Class\nLocation Workshop presentations are on the below link:\nhttp://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=95\n• More efficient and practical class location approaches that provide appropriate safety and\navoid unnecessary costs such as unnecessary pipe replacement.\nPHMSA will continue to study and consider if adjustments are needed to class location\nrequirements. PHMSA will consider these issues in the context of other issues it is addressing\nrelated to new construction quality management systems (QMS) and safety management systems\n(SMS). PHMSA will also consider inspection findings, IM assessments, and lessons-learned\nfrom past incidents. Any changes to the definition and application of class locations in 49 CFR\nPart 192 will require a very thorough process. PHMSA plans to further evaluate the feasibility\nand the appropriateness of each alternative, continue to reach-out to all stakeholders, consider\ninput from all sources, and consider future rulemaking if a cost-effective and safety focused\napproach to adjusting specific aspects of class location requirements can be developed in order to\naddress the issues identified by industry.\n4 PHMSA did not analyze the cost. The potential pros and cons are highlighted in Section 3 of this report.\nDepartment of Transportation vi Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 8>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\n1. INTRODUCTION\nThe Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (the Act), Section 5,\nrequires the Secretary of Transportation to evaluate and issue a report evaluating whether IM\nsystem requirements, or elements thereof, should be expanded beyond HCAs and, with respect to\ngas transmission pipeline facilities, whether applying IM program requirements to these\nadditional areas would eliminate or reduce the need for class location requirements.\nIn conducting the evaluation the Act required the following, at a minimum, to be considered:\n1. Continued protections for public safety;\n2. Continued reduction of risk in HCAs;\n3. Cost of applying IM standards to pipelines outside of HCAs where operators are already\nconducting assessments beyond what is required under Chapter 601 of Title 49, United\nStates Code;\n4. Achievable and sustainable IM assessments and repairs with limited disruption in\npipeline service;\n5. Options for phasing in any extension of IM requirements beyond HCAs, including the\nmost effective and efficient options for decreasing risks to an increasing number of\npeople living or working in proximity to pipeline facilities; and\n6. The appropriateness of applying repair criteria, pressure reductions, and other special\nsafety requirements for scheduling remediation to areas outside of HCAs.\nTo perform the evaluation, PHMSA solicited comments from stakeholders including industry\nrepresentatives, pipeline operators, regulatory agencies, and public interest groups.\n2. EXPANSION OF IM REQUIREMENTS BEYOND HCAs\n(The Act § 5(a)(1))\n2.1 History of IM Program\n2.1.1 History of Hazardous Liquid IM Program\nOn October 24, 1992, the Pipeline Safety Act of 1992 (Pub. L. 102-508) was enacted\nestablishing the foundation for taking a risk-based approach to pipeline safety. 5 The law\ndirected DOT, through the Research and Special Programs Administration (RSPA), a\npredecessor agency to PHMSA, to prescribe, if necessary, additional standards requiring the\nperiodic inspection of each pipeline in high population density areas or in areas unusually\nsensitive to environmental damage (collectively referred to as high consequence areas or HCAs).\nIn response to this directive, the Office of Pipeline Safety (OPS) 6 created several initiatives,\nsome of which include the Risk Management Demonstration Program and the Systems Integrity\nInspection Program. In 1999, OPS held a public meeting7 to consider the lessons learned from\n5 Two years later, Public law 103-272 re-codified many provisions of this Act in Title 49 U.S. Code.\n6 OPS is the office within PHMSA that carries out national programs to ensure the safe, reliable and environmentally\nsound operation of the United States pipeline transportation systems.\n7 Federal Register (64 FR 56725, October 21, 1999).\nDepartment of Transportation 1 Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 9>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\nthese initiatives. The goal was to evaluate the need for additional regulations to provide greater\nassurance of pipeline integrity in high-density population areas, waters where a substantial\nlikelihood of commercial navigation exists, and areas unusually sensitive to environmental\ndamage. At this public meeting, OPS expressed its intent to incorporate a process into its\nregulations to validate pipe integrity in these HCAs. The resulting hazardous liquid pipeline IM\nregulations were implemented in two phases. The first phase was IM regulations for operators\nwith 500 miles (or more) of hazardous liquid pipelines8 and the second phase was for operators\nwith less than 500 miles of hazardous liquid pipelines.9\n2.1.2 History of Gas Transmission Integrity Management Program\nBeginning in January 2000, OPS began meeting with industry groups, research institutions, gas\ntransmission operators, state pipeline safety agencies, public interest parties, and other groups of\ninterest to gain a clear understanding of the characteristics of a gas transmission pipeline incident\nin order to develop a definition of a HCA for gas transmission pipelines. A public meeting was\nheld to solicit comments on Gas Transmission Pipeline Integrity Management in HCAs.\n10 A\nsecond public\nmeeting11 was held to seek further information and clarification and obtain further public\ncomments on IM concepts as they apply to gas transmission pipelines. At the second public\nmeeting, OPS provided elements of a proposed gas transmission pipeline IM program.\nSubsequently, OPS published the first definitions of what defines a Gas Transmission HCA.\n12\nHCAs were initially defined as:\n• Class 3 and Class 4 location;\n• An area where a pipeline is within 660 feet (1000 feet where the pipeline is 30 inches in\ndiameter and operates at a MAOP of 1000 psig or more) of a hospital, school day-care\nfacility, retirement facility, prison or other facility having persons who are confined, are\nof impaired mobility, or would be difficult to evacuate; and\n• An area where a pipeline lies within 660 feet (1000 feet where the pipeline is 30 inches in\ndiameter and operates at an MAOP of 1000 psig or more) where 20 persons congregate at\nleast 50 days in any 12 month period.\nThe definition of an HCA was finalized on August 6, 2002.13 The only change from the January\n9, 2002, definition was that for pipelines 12 inches or less in diameter and operating at an MAOP\nof less than 1200 psig, an HCA was an area where a pipeline is within 300 feet of a building\noccupied by persons who are confined, are of impaired mobility, or would be difficult to\nevacuate. For pipelines greater than 12 inches in diameter, the distance was 660 feet and 1000\n8 Federal Register (65 FR 75378, December 1, 2000).\n9 Federal Register (67 FR 2136, January 16, 2002).\n10 Federal Register (66 FR 848, January 4, 2001).\n11 Federal Register (66 FR 34318, June 27, 2001).\n12 Federal Register (67 FR 1108, January 9, 2002).\n13 Federal Register (67 FR 50824, August 6, 2002).\nDepartment of Transportation 2 Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 10>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\nfeet for pipelines greater than 30 inches in diameter and operating at greater than 1000 psig\nMAOP.14\nOn December 17, 2002, the PSIA of 2002 was signed into law (Pub. L. 107-355). Section 14,\n“Risk Analysis and Integrity Management Programs for Gas Pipelines,” required the Secretary of\nTransportation to develop and implement an IM program for gas transmission pipeline facilities.\nA NPRM15 was published proposing requirements to implement Section 14 of the PSIA of 2002.\nThese NPRM requirement areas included:\n• Intervals for conducting baseline and reassessment testing;\n• Consideration of pressure testing conducted prior to the final rule;\n• Incorporation of issues raised by state and local authorities;\n• Conducting of pressure testing in an environmentally appropriate manner;\n• Operator notification to RSPA of changes to its IM program; and\n• Record sharing of operator records with state interstate agents.\nIn this NPRM, OPS proposed a change to the definitions of a HCA. The concept of a covered\nsegment was introduced. A covered segment was defined as the length of gas transmission\npipeline that could potentially impact an HCA.16 Previously, only distances from the pipeline\ncenterline were discussed in relation to HCA definitions. The concept of using Potential Impact\nCircles, Potential Impact Zones, and Potential Impact Radii to identify covered segments, instead\nof a fixed corridor width, was introduced.17\nFollowing the publication of the NPRM, RSPA held workshops and public meetings18 to solicit\ncomments on the proposed gas transmission pipeline IM regulations. The culmination of these\npublic meetings was the issuance of the Gas Transmission Pipeline Integrity Management final\nrule on December 15, 2003,19 which added Subpart O, “Gas Transmission Pipeline Integrity\nManagement” to 49 CFR Part 192.\n14 The influence of the existing class location concept on the early definition of HCAs is evident from the use of\nclass locations themselves in the definition, and the use of fixed 660 ft. distances which corresponds to the\ncorridor width used in the class location definition. This concept was later significantly revised, as discussed\nlater, in favor of a variable corridor width (referred to as the Potential Impact Radius) based on case-specific pipe\nsize and operating pressure.\n15 Federal Register (68 FR 4278, January 28, 2003).\n16 HCA and PIR definitions can be found in 49 CFR § 192.903.\n17 The use of the PIR to define high consequence areas is a significant aspect of IM and greatly influences the notion\nthat the existing class location approach might be outdated and might mitigate the need for class locations. That\nissue, and the contrast between the two approaches is discussed in Section 3 of this report.\n18 Federal Register (68 FR 6385, February 7, 2003); Federal Register (68 FR 9966, March 3, 2003); and Federal\nRegister (68 FR 17594, April 10, 2003).\n19 Federal Register (68 FR 69778, December 15, 2003).\nDepartment of Transportation 3 Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 11>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\n2.2 ANPRM: Safety of Hazardous Liquid Transmission Pipelines\nIn October 2010, PHMSA published an ANPRM seeking comments on revising the pipeline\nsafety regulations applicable to the safety of hazardous liquid pipelines.\n20 PHMSA stimulated\nfeedback by asking a series of detailed questions in six (6) specific topic areas related to\nhazardous liquid pipelines. These topic areas included:\n• Scope of the pipeline safety regulations and existing regulatory exceptions;\n• The criteria for designation as a HCA;\n• Leak detection and Emergency Flow Restricting Devices (EFRD);\n• Valve spacing;\n• Repair criteria in non-HCA areas; and\n• Stress corrosion cracking (SCC).\nUnder each of these specific topic areas PHMSA requested responses to these questions. In\nresponse to the ANPRM, PHMSA received 24 comments which are available in the docket21 at\nregulations.gov. The pipeline industry consensus was that the regulations as written were\nadequate. The industry asserted that significant improvement in the safety record of hazardous\nliquid pipelines had been made since the promulgation of IM rules and any modifications to the\nregulations should be limited. On the issue of repairs in non-HCA areas, industry representatives\nfelt that assessments were being performed in non-HCA areas and that IM repair criteria would\nbe voluntarily applied to any anomalies found in these areas.\n2.3 ANPRM: Safety of Gas Transmission Pipelines\nDuring August 2011, PHMSA published an ANPRM seeking comments on revising the pipeline\nsafety regulations applicable to the safety of gas transmission pipelines.22 PHMSA stimulated\nfeedback by asking a series of detailed questions in 15 general topic areas related to gas\ntransmission pipelines, gas gathering pipelines, and underground storage facilities. The general\ntopic areas relating to gas transmission IM and expanding IM programs outside of HCAs in this\nANPRM included:\n• Whether IM requirements should be changed;\n• Whether issues related to system integrity should be addressed by expanding non-IM\nrequirements;\n• Whether the definition of a HCA should be revised; and\n• Whether additional restrictions should be placed on the use of specific pipeline\nassessment methods.\nIn response to the ANPRM, PHMSA received over 100 comments letters containing over 1,400\nindividual comments, which are available on the docket.23 Significant and extensive comments\n20 Federal Register (75 FR 63774, October 18, 2010).\n21 Docket PHMSA-2010-0229.\n22 Federal Register (76 FR 53086, August 25, 2011).\n23 Docket PHMSA-2011-0023 found at regulations.gov.\nDepartment of Transportation 4 Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 12>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\non the topic of expanding IM were provided. The input generally fell into three broad\ncategories:\n1. Those who advocated the significant expansion of the full IM program to more pipeline\nsegments (i.e., redefining HCAs to encompass more pipe segments, some of which\nadvocated incorporation of critical infrastructure and/or additional class locations for\nurban, densely populated areas using even more stringent design safety factors than\ncurrently required by 49 CFR Part 192);\n2. Design safety factors are factors that ensure the pipeline operating pressures are operated\nbelow 100 percent of the maximum pipe strength. Design safety factors are developed\nbased upon risk to the public (number of human dwellings near the pipeline or type of\ndwelling – hospital, school, or nursing care facility) and for piping that may have\nadditional operational stresses such as compressor stations, metering stations,\nfabrications, river crossings, and road/railroad crossings. Safety factors for the pipeline\nvary― Class 1, with a design factor of 0.72; Class 2, with a design safety factor of 0.60;\nClass 3, with a design safety factor of 0.50, and Class 4, with a design safety factor of\n0.40. The lower the safety factor the stronger the pipe must be for the MAOP of the\npipeline through thicker pipe and/or higher steel grades. Those who advocated that more\nstringent and/or more prescriptive standards be applied to existing IM requirements (in\nlieu of performance-based or programmatic requirements); and\n3. Those who advocated that the existing IM rules were appropriate and that industry should\nbe permitted to apply IM principles to non-HCA pipe segments in a voluntary basis.\nSpecifically, INGAA and a number of gas transmission pipeline operators noted that this was an\nopportune time for considering the next steps in IM, since baseline assessments under the current\nIM rules were being completed. INGAA noted its policy goal was to apply IM principles (as\ndescribed in the national consensus standard ASME/ANSI B31.8S) beyond HCAs, covering 90\npercent of people living near transmission pipelines by 2020 and 100 percent by 2030.24\nSimilarly, TransCanada submitted information in support of INGAA’s proposal, noting that by\nthe end of 2012 the company will have assessed more than 85 percent of its U.S. pipeline\nmileage covering more than 95 percent of people living near their pipelines. However,\nTransCanada stated that it believed significant technological challenges would be encountered if\nIM regulations were extended to all pipeline segments as noted:\nTransCanada stated “achieving the goal of 100% population coverage is not without its\nchallenges. This incremental mileage contains significant technical and operational\nchallenges including; small diameter pipelines, single source feeds to customers, multi-\ndiameter pipelines, low flow pipelines that would preclude the use of free-swimming in-line\ninspection tools, and station piping which contains complex geometries and excavation\nchallenges due to nearby piping and other underground utilities. The availability of\nimproved integrity management principles, including new technology, will be important as\n24 Letter from Terry D. Boss, Senior Vice President of Environment, Safety and Operations, Interstate Natural Gas\nAssociation of America, Safety of Gas Transmission Pipelines, Docket No. PHMSA-2011-0023, dated January 20,\n2012. http://www.regulations.gov/#!documentDetail;D=PHMSA-2011-0023-0082\nDepartment of Transportation 5 Pipeline and Hazardous Materials\nSafety Administration\n\n<<<PAGE 13>>>\n\nReport to Congress\nEvaluation of Expanding Integrity Management\nBeyond HCAs and Whether Expansion Would Mitigate the\nNeed for Class Location Requirements April 2016\nwe address these hard-to-assess areas. We will continue to support and participate in R&D\nefforts including development of new inspection and assessment technology to facilitate this\ngoal.”\nPHMSA is not proposing additional IM regulations to take the place of class locations.\n2.4 Expanding IM Requirements to Areas Outside HCAs\nPHMSA has carefully considered the extensive input and comments received to date and plans to\npropose an approach that balances the need to provide additional protections for persons within\nthe PIR of a pipeline (but that is not a defined HCA), and the need to prudently apply IM\nresources in a fashion that continues to emphasize the priority of HCAs. PHMSA, therefore, is\nconsidering an approach that would require selected aspects of IM programs (namely, integrity\nassessments and repair criteria) to apply to non-HCA segments. For hazardous liquid pipelines,\nPHMSA would propose to apply these requirements for non-HCA pipeline segments. For gas\ntransmission pipelines, PHMSA would propose to apply these requirements where persons live\nand work and could reasonably be expected to be located within a pipeline PIR. PHMSA would\npropose to promulgate a rule that would require that integrity assessments be conducted, and that\nsignificant anomalies and defects be repaired in a timely manner, using similar standards in place\nfor HCAs. However, some of the other program elements of the IM program requirements\ncontained in 49 CFR Part 192, Subpart O, or 49 CFR § 195.452 (as applicable) would not be\nmandatory for non-HCA segments.\n2.4.1 Hazardous Liquid\nPeriodic assessments, particularly with inline inspection (ILI) tools, provide critical information\nabout the condition of a pipeline, but are currently only required under the IMP requirements\nfound in §§ 195.450 and 195.452. PHMSA believes that pipeline operators should be required to\nhave the information needed to promptly detect and remediate conditions that could adversely\naffect the safe operation","truncated":true,"body_characters":154208}