Gas Gathering Final Rule Summary
PHMSA's Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments, rule was issued on the Federal Register today with the published version expected on Monday November 15, 2021. Elemental experts have reviewed the issued rule and summarized the biggest changes below. If you need assistance with determining how or if these regulations apply to your operations contact Elemental at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com.
Summary
The Gas Gathering Final Rule contains provisions which expand federal regulations and safety oversight to all onshore gas gathering pipelines.
The biggest highlights of the Final Rule include the designation of two new pipeline regulatory types: Type C and Type R Gathering Lines.
Type C Gathering Lines
Class 1 gathering lines greater than or equal to 8 inches in diameter and operating at a hoop stress of 20% specified minimum yield strength (SMYS) or more are now classified as Type C regulated gathering lines.
Regulated onshore gathering refers to Type A, Type B, or Type C gathering lines as determined in 49 CFR 192.8
Type C Requirements for Pipe 8-inches or Larger
Within one year of the effective date, all Type C gathering lines must comply with the following requirements:
Type C pipe and components made with composite materials must comply with the portions of 49 CFR 192 Subparts B through G and subpart J applicable to transmission lines for all design, installation, construction, initial inspection, and initial testing of new, replaced, or otherwise changed pipe.
For metallic Type C lines, corrosion control according to the requirements of 49 CFR 192 Subpart I applicable to transmission lines.
Damage prevention measures in accordance with 49 CFR 192.614.
Emergency plan procedures must be developed and implemented in accordance with 49 CFR 192.615.
A public awareness program must be developed and implemented in accordance with 49 CFR 192.616.
Line markers must be installed and maintained according to the requirements for transmission lines as described in 49 CFR 192.707.
Conduct leakage surveys in accordance with 49 CFR 192.706 and repair hazardous leaks in accordance with 49 CFR 192.703(c).
Type C Requirements for Pipe 12-inches or Larger
If the pipeline contains plastic pipe, then the operator must comply with all the requirements of 49 CFR 192 applicable to plastic pipe and components ( this does not include pipe and components made of composite materials that include plastic in the design).
MAOP must be established through either a pressure test that meets the requirements of 49 CFR 192, or according to the highest operational pressure during the 5 years before the effective date of the rule.
Type R Gathering Lines
Type R Gathering Lines are defined in 49 CFR 192.8 and include all Class 1 and Class 2 gathering lines not designated as Type A, Type B, or Type C gathering lines. These are subject to reporting under 49 CFR 191 but are not subject to requirements in 49 CFR 192. Therefore, they are categorized as Reporting-Regulated Gathering Lines.
Type R gathering lines do not need to submit information to NPMS or perform Safety Related Condition reporting.
Other Regulations Applicable to Gas Gathering Lines
Gas gathering lines will be folded into several existing regulations that previously applied to transmission lines and components.
Incidental Gathering
New, replaced, or relocated lines may not be classified as incidental gathering lines if they are more than 10 miles in length.
Composite Materials
Operators can apply to use composite materials not otherwise allowed under 49 CFR 192 if the operator can meet all the following requirements:
Steel and plastic pipe and components must meet the requirements of 49 CFR 192 Subparts B through G and subpart J applicable to transmission lines.
Operators must notify PHMSA in accordance with 49 CFR 192.18 at least 90 days prior to installing new or replacement pipe or components made of composite materials not otherwise authorized for use in a Type C gathering line. The notification must include a detailed description of the pipeline facilities in which composite materials would be used.
Deadlines
Once the Final Rule goes into effect, gas gathering lines must meet the following deadlines:
Incident reporting for all gas gathering lines, including previously unregulated gathering lines, will be required as of the effective date of the rule.
For Type R lines, annual reporting will be required starting in March of 2023, for calendar year 2022.
Operators must have records showing the beginning and endpoints of gathering lines by November 16, 2022 and these records must be maintained for the life of the pipeline.
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