# 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

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- **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
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- **status:** current
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- **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...
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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. Department of Transportation

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Table of Contents
Executive Summary ...................................................................................................................................... ii
1. INTRODUCTION ................................................................................................................................ 1
2. EXPANSION OF IM REQUIREMENTS BEYOND HCAs (The Act § 5(a)(1)) ................................ 1
2.1 History of IM Program .................................................................................................................. 1
2.1.1 History of Hazardous Liquid IM Program............................................................................ 1
2.1.2 History of Gas Transmission Integrity Management Program ............................................. 2
2.2 ANPRM: Safety of Hazardous Liquid Transmission Pipelines .................................................... 4
2.3 ANPRM: Safety of Gas Transmission Pipelines .......................................................................... 4
2.4 Expanding IM Requirements to Areas Outside HCAs ................................................................. 6
2.4.1 Hazardous Liquid ......................................................................................................................... 6
2.4.2 Gas Transmission ......................................................................................................................... 7
2.4.3 Notice of Proposed Rulemaking ................................................................................................. 10
3. DOES EXPANSION OF IM BEYOND HCAs MITIGATE THE NEED FOR CLASS
LOCATIONS? (The Act § 5(a)(2)) ............................................................................................................ 11
3.1 Class Locations (Background) .................................................................................................... 11
3.1.1 History of Class Locations .................................................................................................. 11
3.1.2 Purpose of Class Locations ................................................................................................. 14
3.2 ANPRM: Safety of Gas Transmission Pipelines ........................................................................ 22
3.3 Notice of Inquiry: Class Location Requirements ........................................................................ 24
3.3.1 History leading up to Request for Comments on Class Location Regulations ................... 24
3.3.2 Summary of Comments Received on Need for Modifying Class Locations ........................ 24
3.4 Pipeline Advisory Committee Meeting ....................................................................................... 25
3.5 Class Location Workshop ........................................................................................................... 27
3.6 Class Location Approach versus IMP Approach ........................................................................ 34
3.7. Alternatives to Class Locations ................................................................................................... 38
3.7.1 Single Design Factor .......................................................................................................... 38
3.7.2 Sliding Mile Based upon Potential Impact Radius ............................................................. 38
3.7.3 Expand Class Locations ...................................................................................................... 42
3.7.4 Bifurcated Approach ........................................................................................................... 42
3.7.5 Revise §192.611 to Include Additional IM Oriented Methods for Addressing Class
Location Changes ............................................................................................................................... 42
3.7.6 No Change in Class Location Methodology ....................................................................... 42
4. CONCLUSION ................................................................................................................................... 43
5. FUTURE CONSIDERATION OF CLASS LOCATION ................................................................... 43
Appendix A - Abbreviations ..................................................................................................................... A-1
Appendix B – Class Location Waiver Criteria ......................................................................................... B-1
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Report to Congress
Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
Executive Summary
Section 5(c) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (the Act)
(Pub. L. 112-90) requires the Secretary of Transportation to “evaluate (1) whether integrity
management (IM) system requirements, or elements thereof, should be expanded beyond high
consequence areas (HCAs); and (2) with respect to gas transmission pipeline facilities, whether
applying IM program requirements, or elements thereof, to additional areas would mitigate the
need for class location requirements.” Section 5(f) of the Act authorized the Pipeline and
Hazardous Materials Safety Administration (PHMSA) to issue regulations in accordance with
the report after the conclusion of a review period. This report documents that evaluation and
addresses whether IM program requirements should be expanded beyond high consequence areas
(HCAs) and, specifically for gas transmission pipelines regulated under 49 Code of Federal
Regulations (CFR) Part 192, whether such expansion would mitigate the need for class location
designations and corresponding requirements. PHMSA conducted a class location public
meeting on April 16, 2014, and requested public comments to be submitted to Docket Number
PHMSA-2013-01611 located on the internet at regulations.gov. Public comments received on
the docket were evaluated.
In October 2010 and August 2011, PHMSA published notices in the Federal Register to solicit
comments on revising the pipeline safety regulations applicable to hazardous liquid and natural
gas transmission pipelines including expansion of IM program requirements beyond HCAs. In
general, industry representatives and pipeline operators were opposed to any expansion of HCAs
and in favor of eliminating class locations on newly constructed pipelines, whereas public
interest groups were in favor of expanding HCAs but against curtailing class location
requirements.
PHMSA has carefully considered the input and comments. At this time, PHMSA plans to
propose an approach that balances the need to provide additional protections for persons within
the potential impact radius (PIR) of a pipeline rupture (outside of a defined HCA), and the need
to prudently apply IM resources in a fashion that continues to emphasize the risk priority of
HCAs. PHMSA, therefore, is considering an approach that would require selected aspects of IM
programs (namely, integrity assessments and repair criteria) to be applicable for non-HCA
segments. For hazardous liquid pipelines, PHMSA would propose to apply these requirements
for non-HCA pipeline segments.
2 For gas transmission pipelines, PHMSA would propose to
apply these requirements where persons live and work and could reasonably be expected to be
located within a pipeline PIR. Under this approach, PHMSA would propose requirements that
1 On August 25, 2011, (76 FR 53086) PHMSA published in the Federal Register an Advance Notice of Proposed
Rulemaking (ANPRM) titled: “Safety of Gas Transmission Pipelines” seeking comments on the need for changes
to the regulations covering gas transmission pipelines. Public comments from this ANPRM are posted on Docket
Number PHMSA-2011-0023 located on the internet at regulations.gov.
2 Gas and Hazardous Liquid (HL) Notices of Proposed Rulemaking (NPRM) both protect the safety of humans in a
similar manner. The difference is the environmental effects of HL versus gas releases on the environment
including the effects on soils, streams, and rivers. Due to gas being lighter than air, gas rises up and does not
pollute soil, streams, and rivers compared to hazardous liquids such as crude oil which is heavier than air.
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Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
integrity assessments be conducted, and that injurious anomalies and defects be repaired in a
timely manner, using similar standards in place for HCAs. However, the other program elements
of a full IM program contained in 49 CFR Part 192, Subpart O, or 49 CFR Section 195.452 (as
applicable) would not be required for non-HCA segments.
The Act also required the Secretary of Transportation to evaluate if expanding IM outside of
HCAs for gas transmission pipelines, as discussed above, would mitigate the need for class
location requirements.
Expanding IM Requirements Beyond HCAs
Based upon findings from lessons learned, accident investigations, assessments, IM, and
operations and maintenance (O&M) considerations, PHMSA is proposing through a notice of
proposed rulemaking (NPRM) to apply selected IM program elements (i.e. assessments and
remediation on a continuing interval) to areas outside HCAs. For gas transmission pipelines, the
assessment and remediation requirements would be limited to selected areas outside HCAs
identified in this report as moderate consequence areas (MCAs). This integrity assessment
approach for non-HCA locations is addressed in separate NPRMs for both gas transmission and
hazardous liquid pipelines.
Class Location
On August 1, 2013, PHMSA published a notice in the Federal Register (78 FR 46560) soliciting
comments on expanding gas IM program requirements and mitigating class location
requirements (Class Location Notice). Comments in the Class Location Notice were solicited on
whether:
1. PHMSA should increase the existing class location design factors in densely populated
areas with building over four stories?
2. Class locations should be eliminated and a single design factor used, if IMP requirements
are expanded beyond HCAs?
3. Should there be only a single design factor for pipeline areas where there are large
concentrations of populations along the pipeline; 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?
A class location workshop was held on April 16, 2014, to discuss this notice and comments were
received from stakeholders, including industry representatives, pipeline operators, state
regulatory agencies, and the public. Based on PHMSA’s evaluation of written comments and
stakeholder input at the workshop, PHMSA considered several alternatives for changing the
current regulations with respect to defining class locations and how to approach changes in class
location, when they occur, which include:
Single Design Factor
PHMSA solicited comments on the use of a single design factor for all pipeline class locations as
an alternative to the current method for determining class locations. The proposal was to use a
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Report to Congress
Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
higher design factor where there are large concentrations of populations, such as schools,
hospitals, nursing homes, multiple-story buildings, stadiums, and shopping malls.
The comments on the use of a single design factor were overwhelmingly negative. Commenters
felt that, to mitigate class locations by going to a single design factor approach would impact too
many of the existing requirements in 49 CFR Part 192, including design, construction, and
operational inspections and would be complicated to implement and may result in a decrease in
safety in populated areas.
Sliding Mile Based upon Potential Impact Radius
The current sliding mile methodology for determining a class location unit could be replaced by
a methodology based on the HCA PIR. Some pipeline industry comments suggested this
approach may have merit for new and replaced pipe instead of existing pipe. An additional
safety factor would be considered if this method were proposed. One operator proposed a
method similar to the PIR approach. The operator called it “the Class Location Circle”
approach. The Class Location Circle would be either 300 feet in radius or the PIR of the pipeline
whichever results in a larger area. Also, another operator proposed a redefinition of the class
location densities over those currently found in 49 CFR Section 192.5.
Expand Class Locations
Gas transmission pipelines are currently classified as Class 1, 2, 3, or 4 locations. A Class 4
location is defined as a class location where buildings of four (4) or more stories are prevalent.
Heavily developed urban areas have many buildings over four stories high. While some
commenters felt that the existing class location approach should be retained and expanded to
include additional class locations for densely populated urban areas with buildings over four
stories tall, a majority of industry and operator commenters were against adding additional class
locations. The industry representatives and pipeline operators felt that new class locations with
design factors lower than the current 0.4 design factor for Class 4 locations would make it
difficult to continue to supply natural gas to the newly classified areas.
Bifurcated Approach
The Interstate Natural Gas Association of America (INGAA) submitted a written request to keep
the current method for existing pipelines, but add a new method using the PIR approach for new
construction and replaced pipelines. This approach would utilize the HCA PIR type approach
for new or replaced pipelines only and would keep the current class location definitions and
applications for existing pipelines.
INGAA’s bifurcated approach would allow class location changes to existing pipe including pre-
Code pipe with additional operational and integrity measures, and new pipelines with a single
design factor in all class locations to have additional material, construction and integrity
measures.
Class Location Changes – Allow Additional IM Assessments
One alternative being considered is to retain the current method for determining class locations
but to revise the regulations for addressing changes in class locations. Such changes might
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Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
include alternatives in addition to pipe replacement, retesting, or de-rating, such as incorporation
of IM practices to validate the condition of the pipe and monitor the pipe within an IM process.
Specifically, the INGAA suggested that PHMSA consider and engage stakeholders regarding
eighteen categories of standards or requirements that could be developed through rulemaking to
replace the current Class Location Special Permits program. The eighteen categories suggested
by INGAA are similar to the conditions PHMSA has used in granting class location special
permits. Such an approach would provide regulatory certainty.
No Change
Retain the current 49 CFR Part 192 methods for determining class location (definition) and class
location changes along with the requirements that correspond with those designations, including
Maximum Allowable Operating Pressure (MAOP), pressure testing, operational inspections and
inspection intervals.
Conclusion
Overall, the majority of stakeholder responses suggested that PHMSA not change the current
class location approach for class locations and class location changes as population increases
used for establishing MAOP and O&M surveys for existing pipelines. For new transmission
pipelines, some industry groups and operators supported some type of bifurcated approach for
existing and new pipelines as described above. Other commenters suggested alternatives to
requirements that sometimes result in pipe replacement when class location changes.
For gas transmission pipelines, PHMSA believes the application of IM assessment and
remediation requirements to MCAs does not warrant elimination of class locations. Class
locations affect all gas pipelines, including transmission (interstate and intrastate), gathering, and
distribution pipelines, whether they are constructed of steel pipe or plastic pipe. Class location is
integral to determining MAOPs, design pressures, pipeline repairs, HCAs, and O&M inspections
and surveillance intervals.
3 Class locations affect 12 subparts and 28 sections of 49 CFR Part
192 for gas pipelines. The subparts and sections are listed and discussed in Sections 3.1.2.4 and
3.7.2.2. While assessment and remediation of defects on gas transmission pipelines is an
important risk mitigation program, it does not adequately compensate for other aspects of class
location as it relates to other types of gas pipelines and as it relates (for all gas pipelines) to the
original pipeline design and construction such as the design factor, initial pressure testing,
establishment of MAOP, O&M activities, and other aspects of pipeline safety, that are based on
class location. Also, there are some disadvantages to using only the PIR circle method without
inclusion of class locations that use human dwelling counts or buildings within the PIR. For
instance: (a) PIR approach may exclude buildings/homes for PIRs less than 660 feet, which
could be impacted from a pipeline rupture and are now included in the class location unit, (b)
PIR approach does not take into account pipe wall thickness, grade, seam type, testing history, or
3 PIR could be used as an alternative to the class location spacing unit (§ 192.5(a)(1)) of 220 yards (660 feet) on
either side of the pipeline used to determine class locations for new pipelines. The class location dwelling count
would need to have similar numbers as defined in § 192.5 for either the current class location unit or a “PIR
based” class location unit. In this way, the PIR approach could be used to define class locations in order to
construct risk/design factor categories.
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Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
design factor, and (c) it may not take into consideration future development adjacent to PIR
circle without requirements for future surveys. Thus, PHMSA has preliminarily determined to
not eliminate the existing class location requirements. 4
Future PHMSA Consideration of Class Location
PHMSA acknowledges that, although it has decided to not eliminate class location requirements
at this time, industry raised some legitimate issues with the existing rules, or lack thereof, for
implementing class location. PHMSA will continue to listen to stakeholder input and consider:
• Comments and suggested approaches submitted on the docket in response to this report;
Docket Nos. PHMSA-2011-0023, PHMSA -2013-0161 and the April 16, 2014 Class
Location Workshop presentations are on the below link:
http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=95
• More efficient and practical class location approaches that provide appropriate safety and
avoid unnecessary costs such as unnecessary pipe replacement.
PHMSA will continue to study and consider if adjustments are needed to class location
requirements. PHMSA will consider these issues in the context of other issues it is addressing
related to new construction quality management systems (QMS) and safety management systems
(SMS). PHMSA will also consider inspection findings, IM assessments, and lessons-learned
from past incidents. Any changes to the definition and application of class locations in 49 CFR
Part 192 will require a very thorough process. PHMSA plans to further evaluate the feasibility
and the appropriateness of each alternative, continue to reach-out to all stakeholders, consider
input from all sources, and consider future rulemaking if a cost-effective and safety focused
approach to adjusting specific aspects of class location requirements can be developed in order to
address the issues identified by industry.
4 PHMSA did not analyze the cost. The potential pros and cons are highlighted in Section 3 of this report.
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Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
1. INTRODUCTION
The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (the Act), Section 5,
requires the Secretary of Transportation to evaluate and issue a report evaluating whether IM
system requirements, or elements thereof, should be expanded beyond HCAs and, with respect to
gas transmission pipeline facilities, whether applying IM program requirements to these
additional areas would eliminate or reduce the need for class location requirements.
In conducting the evaluation the Act required the following, at a minimum, to be considered:
1. Continued protections for public safety;
2. Continued reduction of risk in HCAs;
3. Cost of applying IM standards to pipelines outside of HCAs where operators are already
conducting assessments beyond what is required under Chapter 601 of Title 49, United
States Code;
4. Achievable and sustainable IM assessments and repairs with limited disruption in
pipeline service;
5. Options for phasing in any extension of IM requirements beyond HCAs, including the
most effective and efficient options for decreasing risks to an increasing number of
people living or working in proximity to pipeline facilities; and
6. The appropriateness of applying repair criteria, pressure reductions, and other special
safety requirements for scheduling remediation to areas outside of HCAs.
To perform the evaluation, PHMSA solicited comments from stakeholders including industry
representatives, pipeline operators, regulatory agencies, and public interest groups.
2. EXPANSION OF IM REQUIREMENTS BEYOND HCAs
(The Act § 5(a)(1))
2.1 History of IM Program
2.1.1 History of Hazardous Liquid IM Program
On October 24, 1992, the Pipeline Safety Act of 1992 (Pub. L. 102-508) was enacted
establishing the foundation for taking a risk-based approach to pipeline safety. 5 The law
directed DOT, through the Research and Special Programs Administration (RSPA), a
predecessor agency to PHMSA, to prescribe, if necessary, additional standards requiring the
periodic inspection of each pipeline in high population density areas or in areas unusually
sensitive to environmental damage (collectively referred to as high consequence areas or HCAs).
In response to this directive, the Office of Pipeline Safety (OPS) 6 created several initiatives,
some of which include the Risk Management Demonstration Program and the Systems Integrity
Inspection Program. In 1999, OPS held a public meeting7 to consider the lessons learned from
5 Two years later, Public law 103-272 re-codified many provisions of this Act in Title 49 U.S. Code.
6 OPS is the office within PHMSA that carries out national programs to ensure the safe, reliable and environmentally
sound operation of the United States pipeline transportation systems.
7 Federal Register (64 FR 56725, October 21, 1999).
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Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
these initiatives. The goal was to evaluate the need for additional regulations to provide greater
assurance of pipeline integrity in high-density population areas, waters where a substantial
likelihood of commercial navigation exists, and areas unusually sensitive to environmental
damage. At this public meeting, OPS expressed its intent to incorporate a process into its
regulations to validate pipe integrity in these HCAs. The resulting hazardous liquid pipeline IM
regulations were implemented in two phases. The first phase was IM regulations for operators
with 500 miles (or more) of hazardous liquid pipelines8 and the second phase was for operators
with less than 500 miles of hazardous liquid pipelines.9
2.1.2 History of Gas Transmission Integrity Management Program
Beginning in January 2000, OPS began meeting with industry groups, research institutions, gas
transmission operators, state pipeline safety agencies, public interest parties, and other groups of
interest to gain a clear understanding of the characteristics of a gas transmission pipeline incident
in order to develop a definition of a HCA for gas transmission pipelines. A public meeting was
held to solicit comments on Gas Transmission Pipeline Integrity Management in HCAs.
10 A
second public
meeting11 was held to seek further information and clarification and obtain further public
comments on IM concepts as they apply to gas transmission pipelines. At the second public
meeting, OPS provided elements of a proposed gas transmission pipeline IM program.
Subsequently, OPS published the first definitions of what defines a Gas Transmission HCA.
12
HCAs were initially defined as:
• Class 3 and Class 4 location;
• An area where a pipeline is within 660 feet (1000 feet where the pipeline is 30 inches in
diameter and operates at a MAOP of 1000 psig or more) of a hospital, school day-care
facility, retirement facility, prison or other facility having persons who are confined, are
of impaired mobility, or would be difficult to evacuate; and
• An area where a pipeline lies within 660 feet (1000 feet where the pipeline is 30 inches in
diameter and operates at an MAOP of 1000 psig or more) where 20 persons congregate at
least 50 days in any 12 month period.
The definition of an HCA was finalized on August 6, 2002.13 The only change from the January
9, 2002, definition was that for pipelines 12 inches or less in diameter and operating at an MAOP
of less than 1200 psig, an HCA was an area where a pipeline is within 300 feet of a building
occupied by persons who are confined, are of impaired mobility, or would be difficult to
evacuate. For pipelines greater than 12 inches in diameter, the distance was 660 feet and 1000
8 Federal Register (65 FR 75378, December 1, 2000).
9 Federal Register (67 FR 2136, January 16, 2002).
10 Federal Register (66 FR 848, January 4, 2001).
11 Federal Register (66 FR 34318, June 27, 2001).
12 Federal Register (67 FR 1108, January 9, 2002).
13 Federal Register (67 FR 50824, August 6, 2002).
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Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
feet for pipelines greater than 30 inches in diameter and operating at greater than 1000 psig
MAOP.14
On December 17, 2002, the PSIA of 2002 was signed into law (Pub. L. 107-355). Section 14,
“Risk Analysis and Integrity Management Programs for Gas Pipelines,” required the Secretary of
Transportation to develop and implement an IM program for gas transmission pipeline facilities.
A NPRM15 was published proposing requirements to implement Section 14 of the PSIA of 2002.
These NPRM requirement areas included:
• Intervals for conducting baseline and reassessment testing;
• Consideration of pressure testing conducted prior to the final rule;
• Incorporation of issues raised by state and local authorities;
• Conducting of pressure testing in an environmentally appropriate manner;
• Operator notification to RSPA of changes to its IM program; and
• Record sharing of operator records with state interstate agents.
In this NPRM, OPS proposed a change to the definitions of a HCA. The concept of a covered
segment was introduced. A covered segment was defined as the length of gas transmission
pipeline that could potentially impact an HCA.16 Previously, only distances from the pipeline
centerline were discussed in relation to HCA definitions. The concept of using Potential Impact
Circles, Potential Impact Zones, and Potential Impact Radii to identify covered segments, instead
of a fixed corridor width, was introduced.17
Following the publication of the NPRM, RSPA held workshops and public meetings18 to solicit
comments on the proposed gas transmission pipeline IM regulations. The culmination of these
public meetings was the issuance of the Gas Transmission Pipeline Integrity Management final
rule on December 15, 2003,19 which added Subpart O, “Gas Transmission Pipeline Integrity
Management” to 49 CFR Part 192.
14 The influence of the existing class location concept on the early definition of HCAs is evident from the use of
class locations themselves in the definition, and the use of fixed 660 ft. distances which corresponds to the
corridor width used in the class location definition. This concept was later significantly revised, as discussed
later, in favor of a variable corridor width (referred to as the Potential Impact Radius) based on case-specific pipe
size and operating pressure.
15 Federal Register (68 FR 4278, January 28, 2003).
16 HCA and PIR definitions can be found in 49 CFR § 192.903.
17 The use of the PIR to define high consequence areas is a significant aspect of IM and greatly influences the notion
that the existing class location approach might be outdated and might mitigate the need for class locations. That
issue, and the contrast between the two approaches is discussed in Section 3 of this report.
18 Federal Register (68 FR 6385, February 7, 2003); Federal Register (68 FR 9966, March 3, 2003); and Federal
Register (68 FR 17594, April 10, 2003).
19 Federal Register (68 FR 69778, December 15, 2003).
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Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
2.2 ANPRM: Safety of Hazardous Liquid Transmission Pipelines
In October 2010, PHMSA published an ANPRM seeking comments on revising the pipeline
safety regulations applicable to the safety of hazardous liquid pipelines.
20 PHMSA stimulated
feedback by asking a series of detailed questions in six (6) specific topic areas related to
hazardous liquid pipelines. These topic areas included:
• Scope of the pipeline safety regulations and existing regulatory exceptions;
• The criteria for designation as a HCA;
• Leak detection and Emergency Flow Restricting Devices (EFRD);
• Valve spacing;
• Repair criteria in non-HCA areas; and
• Stress corrosion cracking (SCC).
Under each of these specific topic areas PHMSA requested responses to these questions. In
response to the ANPRM, PHMSA received 24 comments which are available in the docket21 at
regulations.gov. The pipeline industry consensus was that the regulations as written were
adequate. The industry asserted that significant improvement in the safety record of hazardous
liquid pipelines had been made since the promulgation of IM rules and any modifications to the
regulations should be limited. On the issue of repairs in non-HCA areas, industry representatives
felt that assessments were being performed in non-HCA areas and that IM repair criteria would
be voluntarily applied to any anomalies found in these areas.
2.3 ANPRM: Safety of Gas Transmission Pipelines
During August 2011, PHMSA published an ANPRM seeking comments on revising the pipeline
safety regulations applicable to the safety of gas transmission pipelines.22 PHMSA stimulated
feedback by asking a series of detailed questions in 15 general topic areas related to gas
transmission pipelines, gas gathering pipelines, and underground storage facilities. The general
topic areas relating to gas transmission IM and expanding IM programs outside of HCAs in this
ANPRM included:
• Whether IM requirements should be changed;
• Whether issues related to system integrity should be addressed by expanding non-IM
requirements;
• Whether the definition of a HCA should be revised; and
• Whether additional restrictions should be placed on the use of specific pipeline
assessment methods.
In response to the ANPRM, PHMSA received over 100 comments letters containing over 1,400
individual comments, which are available on the docket.23 Significant and extensive comments
20 Federal Register (75 FR 63774, October 18, 2010).
21 Docket PHMSA-2010-0229.
22 Federal Register (76 FR 53086, August 25, 2011).
23 Docket PHMSA-2011-0023 found at regulations.gov.
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on the topic of expanding IM were provided. The input generally fell into three broad
categories:
1. Those who advocated the significant expansion of the full IM program to more pipeline
segments (i.e., redefining HCAs to encompass more pipe segments, some of which
advocated incorporation of critical infrastructure and/or additional class locations for
urban, densely populated areas using even more stringent design safety factors than
currently required by 49 CFR Part 192);
2. Design safety factors are factors that ensure the pipeline operating pressures are operated
below 100 percent of the maximum pipe strength. Design safety factors are developed
based upon risk to the public (number of human dwellings near the pipeline or type of
dwelling – hospital, school, or nursing care facility) and for piping that may have
additional operational stresses such as compressor stations, metering stations,
fabrications, river crossings, and road/railroad crossings. Safety factors for the pipeline
vary― Class 1, with a design factor of 0.72; Class 2, with a design safety factor of 0.60;
Class 3, with a design safety factor of 0.50, and Class 4, with a design safety factor of
0.40. The lower the safety factor the stronger the pipe must be for the MAOP of the
pipeline through thicker pipe and/or higher steel grades. Those who advocated that more
stringent and/or more prescriptive standards be applied to existing IM requirements (in
lieu of performance-based or programmatic requirements); and
3. Those who advocated that the existing IM rules were appropriate and that industry should
be permitted to apply IM principles to non-HCA pipe segments in a voluntary basis.
Specifically, INGAA and a number of gas transmission pipeline operators noted that this was an
opportune time for considering the next steps in IM, since baseline assessments under the current
IM rules were being completed. INGAA noted its policy goal was to apply IM principles (as
described in the national consensus standard ASME/ANSI B31.8S) beyond HCAs, covering 90
percent of people living near transmission pipelines by 2020 and 100 percent by 2030.24
Similarly, TransCanada submitted information in support of INGAA’s proposal, noting that by
the end of 2012 the company will have assessed more than 85 percent of its U.S. pipeline
mileage covering more than 95 percent of people living near their pipelines. However,
TransCanada stated that it believed significant technological challenges would be encountered if
IM regulations were extended to all pipeline segments as noted:
TransCanada stated “achieving the goal of 100% population coverage is not without its
challenges. This incremental mileage contains significant technical and operational
challenges including; small diameter pipelines, single source feeds to customers, multi-
diameter pipelines, low flow pipelines that would preclude the use of free-swimming in-line
inspection tools, and station piping which contains complex geometries and excavation
challenges due to nearby piping and other underground utilities. The availability of
improved integrity management principles, including new technology, will be important as
24 Letter from Terry D. Boss, Senior Vice President of Environment, Safety and Operations, Interstate Natural Gas
Association of America, Safety of Gas Transmission Pipelines, Docket No. PHMSA-2011-0023, dated January 20,
2012. http://www.regulations.gov/#!documentDetail;D=PHMSA-2011-0023-0082
Department of Transportation 5 Pipeline and Hazardous Materials
Safety Administration

<<<PAGE 13>>>

Report to Congress
Evaluation of Expanding Integrity Management
Beyond HCAs and Whether Expansion Would Mitigate the
Need for Class Location Requirements April 2016
we address these hard-to-assess areas. We will continue to support and participate in R&D
efforts including development of new inspection and assessment technology to facilitate this
goal.”
PHMSA is not proposing additional IM regulations to take the place of class locations.
2.4 Expanding IM Requirements to Areas Outside HCAs
PHMSA has carefully considered the extensive input and comments received to date and plans to
propose an approach that balances the need to provide additional protections for persons within
the PIR of a pipeline (but that is not a defined HCA), and the need to prudently apply IM
resources in a fashion that continues to emphasize the priority of HCAs. PHMSA, therefore, is
considering an approach that would require selected aspects of IM programs (namely, integrity
assessments and repair criteria) to apply to non-HCA segments. For hazardous liquid pipelines,
PHMSA would propose to apply these requirements for non-HCA pipeline segments. For gas
transmission pipelines, PHMSA would propose to apply these requirements where persons live
and work and could reasonably be expected to be located within a pipeline PIR. PHMSA would
propose to promulgate a rule that would require that integrity assessments be conducted, and that
significant anomalies and defects be repaired in a timely manner, using similar standards in place
for HCAs. However, some of the other program elements of the IM program requirements
contained in 49 CFR Part 192, Subpart O, or 49 CFR § 195.452 (as applicable) would not be
mandatory for non-HCA segments.
2.4.1 Hazardous Liquid
Periodic assessments, particularly with inline inspection (ILI) tools, provide critical information
about the condition of a pipeline, but are currently only required under the IMP requirements
found in §§ 195.450 and 195.452. PHMSA believes that pipeline operators should be required to
have the information needed to promptly detect and remediate conditions that could adversely
affect the safe operation
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