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PHMSA Seeks Comment on Whether IMP Expansion Mitigates the Need for Class Locations

By Hunton & Williams LLP on August 1, 2013

As required by Section 5 of the amendments to the Pipeline Safety Act, PHMSA is seeking public comment on whether application of integrity management (IM) requirements beyond high consequence areas would mitigate the need for class location requirements for gas transmission pipelines.  78 F.R. 46560 (August 1, 2013).  PHMSA notes that the IM program provides additional safety for more densely populated areas based on periodic inspections and specified repair deadlines and that substituting an integrity management approach for pre-established class location requirements may allow pipelines to operate at higher pressures while conducting integrity inspections and remediation to maintain safety.  As PHMSA explains, if class location designations are removed from the Part 192 regulations, many regulatory sections would have to be reevaluated.  The Agency asks for comment on 15 questions, many with numerous subparts, geared largely toward whether and how to apply a single design factor if class locations are eliminated.  The comment period ends on September 30, 2013.  The Pipeline Safety Act requires PHMSA to issuing a report to Congress containing with its analysis and findings on this issue by January 3, 2014.

  • Posted in:
    Energy
  • Blog:
    PipelineLaw
  • Organization:
    Hunton Andrews Kurth LLP

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