Key Takeaways
- PHMSA has issued new rules regulating large-diameter, high-pressure gas gathering lines and requiring reporting on all gas gathering lines in Class 1 locations (lower population density, rural areas).
- The extended regulation takes the form of a new Type C gathering line category, defined as gas gathering lines in Class 1 locations that have outside diameters of 8.625 inches or greater and, if steel, operate at stress levels greater than 20% of specified minimum yield strength (SMYS).
- The new rule also places gas gathering lines definition that do not fall into Types A, B, or C into a new category, Type R. The only requirement for Type R lines is incident and annual reporting.
- Operators can request alternative compliance deadlines with a notification to PHMSA.
Setting the Context
With increasing demand for natural gas and the success of shale play hydraulic fracturing in the last decade and a half, production in some areas of the United States has surged. Gathering lines have followed suit, with dramatic growth in both mileage and pipe diameters. The federal Pipeline and Hazardous Materials Safety Administration (PHMSA) estimates that there are currently over 400,000 miles of unregulated onshore gathering lines. Some of the largest are 30 inches in diameter and have an MAOP of 1480 psig – similar to a typical interstate transmission line and vulnerable to the same integrity threats, but exempt from the Federal Pipeline Safety Regulations contained in 49 CFR Parts 191 and 192.
PHMSA concluded that large-diameter, high-pressure gathering lines need to be regulated, and that they would collect and analyze information on gas gathering lines in Class 1 locations (lower population density, rural areas). On November 15, 2021, PHMSA issued the final rule “Pipeline Safety: Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments.” This new rule takes effect on May 16, 2022.
Prior to the new rule, gas gathering lines in Class 1 areas were not federally regulated or reported. Gathering lines in Class 2, 3, and 4 areas were divided into Type A and Type B regulated categories and had to comply with some of the same standards as transmission lines. Pipelines used in production operations and those operating at a vacuum were not regulated – this does not change with the new rule. The new rule does require operators to submit incident and annual reports for all gas gathering facilities and extends regulation to larger gas gathering lines in Class 1 areas that operate at higher pressures.
The extended regulation takes the form of a new Type C gathering line category, defined as gas gathering lines in Class 1 locations that have outside diameters of 8.625 inches or greater and, if steel, operate at stress levels greater than 20% of specified minimum yield strength (SMYS). The requirements for Type C lines vary based on the diameter of the pipeline and proximity to buildings intended for human occupancy and are similar to or less stringent than the regulations for Type B lines. The new rule also places pipelines that meet the gathering line definition but do not fall into Types A, B, or C into a new category, Type R. The only requirement for Type R lines is incident and annual reporting. PHMSA will use the data on Type R lines to evaluate the need for future regulatory scope changes.
How Gathering Line Operators Need to Respond
Determine and Document Gathering Line Extents and Types
A revision to § 192.8 requires operators to maintain records documenting the methodology used to determine the beginning and endpoints of segments determined to be gas gathering lines in accordance with Part 192. For existing lines, these records must be in place by November 16, 2022. These records include the API RP 80 definitions and methods used to define the beginning and endpoints and where those points are located (e.g., mile markers, address, or coordinates). Operators must maintain these records for the life of the pipeline. Operators can request an alternative compliance deadline with a notification to PHMSA if November 16, 2022 is impracticable. This notification must be submitted to PHMSA no later than August 18, 2022.
The flowchart accompanying this article can help you determine whether gathering lines are Type A, B, C, or R. It also helps show what regulations apply to each type. For Type C, the applicable regulations are summarized, but exceptions also apply. See the section of this article on Type C lines for details.
Begin Submitting Incident and Annual Reports for Type R Gathering Lines
A revision to § 191.15 requires operators to submit incident reports for Type R gathering pipelines (those that don’t fit into the Type A, B, or C categories) using a simplified form, DOT Form PHMSA F 7100.2-2. Incident reports will be required for any incidents that occur after May 16, 2022. Type A, B, and C gathering lines will continue to submit reports using existing DOT Form PHMSA F 7100.2.
A revision to § 191.17 requires operators to submit annual reports for Type R gathering lines. The first report for these lines is due no later than March 15, 2023 for the 2022 reporting year. The instructions for DOT Form PHMSA F 7100.2-3 address how to report data that are unknown.
Per changes to § 191.23, Type R gathering lines are exempt from safety-related condition reporting, and a revision to § 191.29 clarifies that the National Pipeline Mapping System requirements in § 191.29 do not apply to any gas gathering lines.
Begin Complying with the Regulations for Type C Gathering Lines
Per the revisions to § 192.9, operators of existing gathering lines that become classified as Type C regulated gathering lines because of the new rule must comply with the new requirements by May 16, 2023. The following base requirements apply to all Type C lines, with additional requirements applied as shown in Table 1.
– Design, Construction, Initial Testing (for new/replaced/relocated/changed lines)
– Damage Prevention
– Emergency plans
Table 1: Additional requirements for certain Type C lines
Operators can request an alternative compliance deadline with a notification to PHMSA if May 16, 2023 is impracticable. This notification must be submitted no later than February 15, 2023.
Conclusion
Most gathering line operators in Michigan and elsewhere will be affected by the new reporting requirements for Type R lines and the requirement to document the determination process, beginning and end points, and types for all gathering lines. Only operators with gathering lines greater than 8” in diameter will be affected by the new Type C requirements. If you need help defining and documenting gathering line extents and types, filing incident or annual reports, updating OM&E manuals, complying with the requirements for newly designated Type C lines, or submitting requests for deadline extensions, please feel free to contact the experts at Acuren.
