Class Location Change Requirements

On Monday October 1, 2018, AGA, APGA, API and INGAA jointly submitted comments in response to PHMSA’s Class Location Change ANRPM. AGA supported PHMSA’s proposal to use integrity management principles as an alternative to existing methods for managing gas transmission pipeline class location changes. Existing requirements to manage class location changes are limited to replacing existing pipelines, pressure testing the pipeline, or reducing the pressure within a pipeline. These measures present reliability concerns for some operators, and may not always be feasible to implement. Advances in technology since the issuance of the existing regulations in 1970 present opportunities to use these technologies with modern integrity assessment programs and principles, without compromising safety. The comments filed also highlight other benefits such as advancing the deployment of new technologies, and incentivizing operators to implement modern inspection technologies.