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PHMSA Final Rule Gas Gathering Line Regulation
- 1. January 2022 GAS GATHERING LINE REGULATION Final Rule
- 2. OVERVIEW Gas Gathering  Transports gas from production to transmission or distribution  API RP80 and §192.8 define start and end points  Currently Regulated  Type A: High Pressure Class 2-4  Type B: Low Pressure Class 2-4  Class 1 is exempt from Parts §191 and §192
- 3. AGENDA  When is the gas gathering rule effective?  What’s in the gas gathering rule? • Clarification of “incidental gathering” • Documenting methodology by which operator determined the beginning and end points of each onshore gathering pipeline it operates • Reporting–regulated gathering requirements (Type R lines) • Regulation of large diameter, high pressure gathering lines (Type C lines) • Composite material use in Type C lines  Q&A
- 4. WHEN IS THE RULE EFFECTIVE? One Year From Effective Date with a Few Exceptions TICK TOCK  Publication Date – November 15, 2021  Effective Date – May 16, 2022
- 5. BOTTOM LINE UP FRONT How Will the New Rule Affect Me? Provision Scope Estimated Mileage Reporting (Incident, annual) Part 191 All gathering >400,000 miles Design, construction, initial inspection and testing All new and replaced Type C (diameter≥ 8.625”) New and replaced only Damage Prevention § 192.614 All Type C (diameter≥ 8.625”) 90,863 miles Emergency plans § 192.615 All Type C (diameter≥ 8.625”) 90,863 miles Public awareness § 192.616 Diameter 8.625” through 16” with a PIR exception All Type C with a diameter> 16” 20,336 miles Line markers § 192.707 Diameter 8.625” through 16” with a PIR exception All Type C with a diameter> 16” 20,336 miles Corrosion control. Subpart I to part 192 Diameter 8.625” through 16” with a PIR exception All Type C with a diameter> 16” 20,336 miles Leakage survey and repairs §§ 192.703, 192.706 Diameter 8.625” through 16” with a PIR exception All Type C with a diameter> 16” 20,336 miles Maximum allowable operation pressure § 192.619 Diameter >12.75” through 16” with a PIR exception All Type C with a diameter> 16” 13,760 miles Plastic pipe requirements Diameter >12.75” through 16” with a PIR exception All Type C with a diameter> 16” 13,760 miles
- 6. WHAT’S IN THE RULE? § 191.1 - Scope What’s New?  (a) Requires incident, SRC, annual, operators registry and other reporting for gas storage facilities and: • Type R gathering lines (Annual 7100.2-1, Incident 7100.2-2) • Type C gathering lines (Annual7100.2-3, Incident 7100.2) Key Exceptions  191.22 (b) (c) and 191.23 exemptions Midstream Impact - Varies  How many new regulated miles do you potentially have?  Automated annual reporting?
- 7. WHAT’S IN THE RULE? § 191.3 - Definitions What’s New?  Regulated onshore gathering pipeline • Type A, Type B or Type C gas gathering line that complies with §192.8  Reporting regulated gathering pipeline • Type R gas gathering line as determined in §192.8 • Subject only to part 191 requirements Key Exceptions  None Midstream Impact – Varies  Class location/PIR analysis for all gathering lines (Type C)  Identify/map unregulated gathering systems (Type R)
- 8. WHAT’S IN THE RULE? § 191.15 – Incident Reports What’s New?  Form for Type R gathering line incidents  May 16, 2022 – Begin incident report submittals Key Exceptions  None Midstream Impact - Varies  Personnel training  Report submissions
- 9. WHAT’S IN THE RULE? § 191.17 – Annual Report What’s New?  (a)(2) Annual reporting for Type R gathering lines  March 15, 2023 - 2022 annual reporting required Key Exceptions  None Midstream Impact - Varies  Personnel training  Report submissions
- 10. WHAT’S IN THE RULE? § 191.23 – Reporting Safety Related Conditions (SRC) What’s New?  (b)(1) Exempts Type R gathering lines from SRC reporting Key Exceptions  None Midstream Impact  None
- 11. WHAT’S IN THE RULE? § 191.29 – National Pipeline Mapping System (NPMS) What’s New?  (c) Clarifies that NPMS submittal does not apply to gathering lines Key Exceptions  None Midstream Impact  None
- 12. WHAT’S IN THE RULE? § 192.3 – Definitions What’s New?  Composite materials means materials used to make pipe or components manufactured with a combination of either steel and/or plastic and with a reinforcing material to maintain its circumferential or longitudinal strength. Key Exceptions  None Midstream Impact  Varies
- 13. WHAT’S IN THE RULE? § 192.8 – How Are Gathering Lines Determined? What’s New?  (a)(5) 10 mile limit on “incidental gathering” pipelines  IG lines > 10 mile length will be considered transmission  Required day final rule effective, May 16, 2022 Key Exceptions  Not retroactive to existing gathering systems Midstream Impact - Moderate  Desktop analysis for new, replaced, or repaired gathering systems
- 14. WHAT’S IN THE RULE? § 192.8 – How Are Gathering Lines Determined? (Cont.) What’s New?  (b) Document the start and end points for all gathering systems  Maintain records for the life of the pipeline  Effective 6 months from date of final rule, Nov 16, 2022 Key Exceptions  Alternate deadline may be considered by PHMSA  Notify PHMSA no later than 90 days prior to deadline Midstream Impact - Moderate  API RP80 analysis for all gathering lines  Requires asset inventory for all gathering
- 15. WHAT’S IN THE RULE? § 192.8 – How Are Gathering Lines Determined? (Cont.) What’s New?  (c) Type R • Non-regulated gathering lines  Type C • Regulated gathering lines • OD ≥ 8.625” and any of the following: ◦ MAOP > 20% of SMYS (steel) ◦ MAOP > 125 psig (steel, incomplete records) ◦ MAOP > 125 psig (non-metallic) Key Exceptions  None Midstream Impact - High  New regulated gathering mileage that requires compliance
- 16. WHAT’S IN THE RULE? § 192.9 – What Requirements Apply to Type C Gathering Lines? What’s New?  “Building intended for human occupancy” (BIFHO) or “other impacted site” • Includes homes, office buildings, factories, outside recreation areas, plant facilities, etc., • Playgrounds, recreation areas, outdoor theaters, or other place of public assembly that is occupied by 20 or more persons on at least 5 days a week for 10 weeks in any 12 month period; or • Any portion of the paved surface, including shoulders, of a designated interstate, other freeway or expressway as well as any other principal arterial roadway with 4 or more lanes, as defined by the FHA Key Exceptions  None Midstream Impact - Moderate  Identify all BIFHO’s and other impacted sites
- 17. WHAT’S IN THE RULE? § 192.9 – What Requirements Apply to Type C Gathering Lines? What’s New?  (e)(1) OD ≥ 8.625” (90,000 miles) • New, replaced, relocated, otherwise modified, converted or reclassified gathering line ◦ Subparts B through G and Subpart J ◦ Subpart I – Corrosion Control (Steel) • Damage prevention, emergency planning, public awareness, line markers, leakage surveys, leak repairs  (e)(2) 12.75” < OD ≤ 16” (20,000 miles) or OD > 16” (14,000 miles) • All of the above plus: ◦ Document MAOP (§192.619 (a) or (c)) and maintain records for life of pipeline ◦ Comply with applicable requirements for plastic pipe/components
- 18. WHAT’S IN THE RULE? § 192.9 – What Requirements Apply to Type C Gathering Lines? Key Exceptions  OD ≤ 16” and contains a PIR/class location unit exception  Not applicable to pipeline lengths ≤ 40 ft. Midstream Impact - High  (g)(4) Compliance achieved within one year of final rule  (5) If change in class location, dwelling density or increase in MAOP cause pipeline to meet Type C definition, compliance required within a year of the change.
- 19. WHAT’S IN THE RULE? § 192.9 – What Requirements Apply to Type C Gathering Lines? Outside diameter Not located near a building intended for human occupancy or other impacted site (§ 192.9(f)) Located near a building intended for human occupancy or other impacted site (§ 192.9(f)) Greater than or equal to 8.625 inches up to and including 12.75 inches • Design, construction, initial testing (new/replaced /relocated/changed lines) • Damage prevention • Emergency plans • Design, construction, initial testing (new/replaced/relocated /changed lines) • Corrosion control • Damage prevention • Emergency plans • Line Markers • Leakage surveys Greater than 12.75 inches up to and including 16 inches • Design, construction, initial testing (new/replaced /relocated/changed lines) • Damage prevention • Emergency plans All Type C requirements Greater than16 inches All Type C requirements All Type C requirements
- 20. WHAT’S IN THE RULE? § 192.9 – What Requirements Apply to Type C Gathering Lines? What’s New?  (h) Requirements for use of composite materials in Type C gathering lines • Comply with subpart B – G and subpart J requirements applicable to transmission lines. • Notify PHMSA (Onerous Process) Key Exceptions  None Midstream Impact  Varies
- 21. D: C: Vice President, Asset Integrity & Corrosion Audubon Companies blouque@auduboncompanies.com 918.514.5879 BRYAN LOUQUE 913.221.3446 auduboncompanies.com
Editor's Notes
- Except: - Reporting + Incident Report Events after May 16, 2022 + Annual report submittal effective March 15, 2023 Identify Type C Lines – Nov 16, 2022 192.9 Compliance – May 16, 2023 MAOP Lookback – 5 year period ending May 16, 2023
- This part prescribes requirements for the reporting of incidents, safety-related conditions, annual pipeline summary data, National Operator Registry information, and other miscellaneous conditions by operators of underground natural gas storage facilities and natural gas pipeline facilities located in the United States or Puerto Rico, including underground natural gas storage facilities and pipelines within the limits of the Outer Continental Shelf as that term is defined in the Outer Continental Shelf Lands Act (43 U.S.C. 1331). This part applies to offshore gathering lines (except as provided in paragraph (b) of this section) and to onshore gathering lines, including Type R gathering lines as determined in § 192.8 of this chapter. 2. Sections 191.22(b), 191.22(c), and 191.23 do not apply to the onshore gathering of gas— (1) Through a pipeline that operates at less than 0 psig (0 kPa); (2) Through a pipeline that is not a regulated onshore gathering pipeline; or (3) Within inlets of the Gulf of Mexico, except for the requirements in § 192.612.
- PHMSA adopted to the industry recommendation to define the new gathering line type as “Type C”
- PHMSA adopted the industry recommendation to adapt the “reporting-gathering” incident report to be fit for purpose
- 1. PHMSA adopted the industry recommendation to exempt “reporting-regulated” lines from SRC reporting
- 1. PHMSA adopted the industry recommendation to adapt the “reporting-gathering” incident report to be fit for purpose
- 1. PHMSA adopted the industry recommendation to clarify that NPMS is not applicable to gathering
- 1. PHMSA adopted the industry recommendation to formally recognize composite materials not currently accepted by code
- 1. PHMSA limits new incidental gathering from to 10 miles; which is less than the 20 miles adopted in RP 1182, but much better than PHMSA’s original proposal of 10 miles. PHMSA acknowledges that the 10-mile limit is only applied to new lines and is not retroactive to existing incidental gathering lines greater than 10 miles.
- 1. 6 months may be a tight timeframe for some companies to identify begin and end points for 10s of thousands of miles of gathering lines.
- (3) For purposes of this section, the term “building intended for human occupancy or other impacted site” means any of the following:  (i) Any building that may be occupied by humans, including homes, office buildings factories, outside recreation areas, plant facilities, etc.;  (ii) a small, well-defined outside area (such as a playground, recreation area, outdoor theater, or other place of public assembly) that is occupied by 20 or more persons on at least 5 days a week for 10 weeks in any 12-month period (the days and weeks need not be consecutive); or  (iii) any portion of the paved surface, including shoulders, of a designated interstate, other freeway, or expressway, as well as any other principal arterial roadway with 4 or more lanes, as defined in the Federal Highway Administration's Highway Functional Classification Concepts, Criteria and Procedures, Section 3.1 (see: https://www.fhwa.dot.gov/planning/processes/statewide/related/highway_functional_classifications/fcauab.pdf).
- 1. Generally, this section is reasonable. It provides for basic requirements for certain pipelines over 8” and also provides for some good exemptions from provision that may not be as important where there are no receptors.  HOWEVER, there is a major concern around the leak survey requirements because: It applies a more stringent standard to Class 1 gathering lines than is applied to Class 1 transmission lines; and May circumvent the express will of Congress as expressed in PIPES 2020 Section 113.  Currently, 192.706 only requires leakage surveys to use “leak detector equipment” when transporting un-odorized gas in Class 3 and Class 4 locations. However, un-odorized transmission lines in class 1 and 2 locations may conduct leakage surveys by other means (e.g. vegetation surveys). The final rule would require a more stringent leakage survey than is required of similarly located transmission lines.  Section 113 of the PIPES Act of 2020 requires that PHMSA promulgate regulations requiring “leak detection and repair programs” using “commercially available advanced technologies” (i.e. leak detector equipment). However, Congress specifically omitted Class 1 regulated gathering lines from this requirement. This new rule appears to circumvent Congress’ express will to not apply such leak detection and repair requirements to Class 1 regulated gathering lines (i.e. Type C). 2. Industry recommended a PIR exemption; however, I have concern about the definition of a “building intended for human occupancy”. As discussed in depth during the RP 1182 deliberations, many operators have “personnel shacks” located at their pipeline stations which are provided to allow operator personnel to get out of the elements while periodically at the station. These are often only periodically used for a few hours a week (not a full time office). RP 1182 recognized that these types of “shacks” should not be the sole reason that a gathering line is excluded from using the PIR exemption; however, the rule as published would make it so.  Preamble The class-location unit moves along the pipeline, and if the sliding mile contains a building intended for human occupancy or other impacted site at any point during the mile's movement, then the exception in paragraph (f) does not apply for the entire mile of pipeline contained within the sliding mile. ….. PHMSA expects that the class location unit method will result in fewer miles of gathering lines being covered by the § 192.9 exception in almost all circumstances because the additional requirements will apply for a mile on each side of a building intended for human occupancy or other impacted site.
- Revise new regulation to be consistent with existing and allow 24 months to comply with the new requirements  Existing Rule 192.611 Change in Class Location ….. 192.611(d) Confirmation or revision of the maximum allowable operating pressure that is required as a result of a study under § 192.609 must be completed within 24 months of the change in class location. Pressure reduction under paragraph (a) (1) or (2) of this section within the 24-month period does not preclude establishing a maximum allowable operating pressure under paragraph (a)(3) of this section at a later date.
- 1. Generally, this section is reasonable. It provides for basic requirements for certain pipelines over 8” and also provides for some good exemptions from provision that may not be as important where there are no receptors.  HOWEVER, there is a major concern around the leak survey requirements because: It applies a more stringent standard to Class 1 gathering lines than is applied to Class 1 transmission lines; and May circumvent the express will of Congress as expressed in PIPES 2020 Section 113.  Currently, 192.706 only requires leakage surveys to use “leak detector equipment” when transporting un-odorized gas in Class 3 and Class 4 locations. However, un-odorized transmission lines in class 1 and 2 locations may conduct leakage surveys by other means (e.g. vegetation surveys). The final rule would require a more stringent leakage survey than is required of similarly located transmission lines.  Section 113 of the PIPES Act of 2020 requires that PHMSA promulgate regulations requiring “leak detection and repair programs” using “commercially available advanced technologies” (i.e. leak detector equipment). However, Congress specifically omitted Class 1 regulated gathering lines from this requirement. This new rule appears to circumvent Congress’ express will to not apply such leak detection and repair requirements to Class 1 regulated gathering lines (i.e. Type C). 2. Industry recommended a PIR exemption; however, I have concern about the definition of a “building intended for human occupancy”. As discussed in depth during the RP 1182 deliberations, many operators have “personnel shacks” located at their pipeline stations which are provided to allow operator personnel to get out of the elements while periodically at the station. These are often only periodically used for a few hours a week (not a full time office). RP 1182 recognized that these types of “shacks” should not be the sole reason that a gathering line is excluded from using the PIR exemption; however, the rule as published would make it so.  Preamble The class-location unit moves along the pipeline, and if the sliding mile contains a building intended for human occupancy or other impacted site at any point during the mile's movement, then the exception in paragraph (f) does not apply for the entire mile of pipeline contained within the sliding mile. ….. PHMSA expects that the class location unit method will result in fewer miles of gathering lines being covered by the § 192.9 exception in almost all circumstances because the additional requirements will apply for a mile on each side of a building intended for human occupancy or other impacted site.
- Notification is made to PHMSA at least 90 days prior to installing new or replacement pipe or components made of composite materials otherwise not authorized for use in Type C gathering pipelines Include beginning and end points of the segment containing composite pipe General description of the ROW including HCAs Relevant pipeline design and construction information including the year of installation Relevant operating information including MAOP, leak and failure history, pressure test info Explanation of the circumstances that the operator believes make the use of composite pipeline material appropriate and how the design, construction, operations, and maintenance will mitigate safety and environmental risks Explanation of procedures and tests that will be conducted periodically over the life of the composite material to document that its strength is being maintained Operations and maintenance procedures that will be applies to the alternative material An explanation of how the use of composite pipeline material would be in the public interest and Certification signed by a vice president of the operator’s company that operation of the applicant's pipeline using composite pipeline material would be consistent with pipeline safety