The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued a Notice of Inquiry (mistakenly labeled in the Federal Register as a Notice of Proposed Rulemaking) concerning class location requirements. PHMSA is seeking public comment on whether applying the integrity management program (IMP) requirements, or elements of IMP, to areas beyond current high consequence areas (HCAs) would mitigate the need for class location requirements for gas transmission pipelines. Section 5 of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 requires the Secretary of Transportation to evaluate and issue a report on whether IMP requirements should be expanded beyond HCAs and whether such expansion would mitigate the need for class location requirements.

Part 192 Regulations Impacted by Class Location

There are indirect or secondary links to class location throughout Part 192. These links include sections that do not specifically mention class location; however, the sections may reference maximum allowable operating pressure (MAOP). If the use of class location designation were to be eliminated or merged, many regulatory sections will need to be reevaluated. The following Subparts would be affected:

Subpart A-General

Subpart B-Materials

Subpart C-Pipe Design

Subpart D-Design of Pipeline Components

Subpart E-Welding of Steel in Pipelines

Subpart G-General Construction Requirements for Transmission Lines and Mains

Subpart I-Requirements for Corrosion Control

Subpart J-Test Requirements

Subpart K-Uprating

Subpart L-Operations

Subpart M-Maintenance

Subpart O-Gas Transmission Pipeline Integrity Management

PHMSA compiled a list of 15 specific areas for comments which is included in this Notice of Inquiry. The public comment period for this notice ends September 30, 2013. You may submit comments identified by the Docket ID PHMSA–2013–0161 via the E-Gov Website.

For a copy of this Notice of Inquiry on Class Location Requirements, contact Jessica Roger