Underground Construction - December 2018 - 9

final rule based on a 2016 proposal that would
require interstate pipelines to expand integrity management to areas beyond high-consequence areas (HCA). The final rule, ostensibly modified by suggestions from a PHMSA
advisory committee, is theoretically due to be
published in March 2019. Because that final
rule will expand IM requirements, INGAA believes that it is now time to provide the pipelines with an IM option for dealing with class
location changes.
PHMSA opens that door in the form of
the ANPR. A number of citizen groups and
the state pipeline safety organization oppose
an IM option to the class location requirements. But C.J. Osman, INGAA director of
operations, safety and integrity, hopes that
as ANPR is discussed, including in the forum
of the advisory committee meetings, opponents can be convinced of the merits of the
INGAA-sought option.
Pipelines can apply for and receive special
permits which allow the circumventing of
class location requirements in certain situations.
Lynda Farrell, executive director, Pipeline
Safety Coalition, a Pennsylvania group, refers
to a National Transportation Safety Board
study and a PHMSA advisory bulletin to underpin her statement that the "ANPRM is premature and that allowing a relaxation of class
location strength requirements is ill advised."
Farrell also refers to the following comments from the National Association of Pipeline Safety Representatives to buttress her
opposition to any changes in class location
requirements.
"Class locations are primarily a design
safety measure. Replacing a design measure
with an operation measure does not improve
safety. Integrity management strategies have
been critically important to pipeline safety
success, but we feel that the reliability of these
measures have not evolved to a level where
their total dependency would be practicable. We have observed some recent accidents
resulting from misapplication in managing
ILI technologies especially when managing
cracks and interactive defects. There are too
many accidents related to mismanagement
of integrity management issues to justify
eliminating class locations in lieu of integrity
management."
The Pipeline Safety Trust acknowledged the
importance of the upcoming IM changes in
the finalization of the 2016 proposed rule and
said any modifications to the class location

requirements should wait until "the gas safety
rule, now in the works for seven years, is complete and the 'IVP' process for identifying and
verifying operator system records is in place
and shown to be working to improve operator
assessments of their systems."
Osman agrees that some of the comments

to the ANPR oppose INGAA's position based
on technical concerns. He acknowledges, "The
onus is on us to prove this is the right change
to make, to explain why the integrity management program offers not just equal protection
but a safer alternative to the current class location method."

ONE CALL FOR
TOTAL PIPING
SOLUTIONS!

ISO 9001:2008Certified Quality
Management System

WE ARE HDPE INTELLIGENCE
Make ISCO your single source! Besides being the industry's leading
distributor of HDPE pipe, call on ISCO for top quality McElroy® fusion
equipment for sale or rent; custom fabrication for tanks, sumps, manholes,
pipe perforation and more; fittings and structures; and the expert
estimating, consultation and training to make it all happen.
Store it. Call it. 1-800-345-ISCO

isco-pipe.com

UConOnline.com | DECEMBER 2018

9
http://www.isco-pipe.com http://www.UConOnline.com
Underground Construction - December 2018

Table of Contents for the Digital Edition of Underground Construction - December 2018
