American Oil & Gas Reporter
WASHINGTON–A pipeline safety regulation published in April by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration goes beyond traditional natural gas transmission to have serious implications for onshore gas gathering.
PHMSA published its long-awaited notice of proposed rule making for natural gas transmission and gathering pipelines on April 8. Under development for more than four years, the NOPR proposes significant changes to the regulations for gas pipeline facilities in 49 CFR Part 192, including regulations for onshore gas gathering lines.
Adopted a decade ago, the current regulations rely, in large part, on American Petroleum Institute Recommended Practice 80, Guidelines for the Definition of Onshore Gas Gathering Lines, which is a voluntary consensus standard for classifying onshore production operations and gas gathering lines. Current regulations contain an exemption for gas gathering lines in rural, Class 1 locations–i.e., areas where 10 or fewer buildings intended for human occupancy are located in the vicinity of a gathering line.
The NOPR proposes to change these regulations by:
• Modifying the requirements for determining whether a pipeline qualifies as an onshore gas gathering line;
• Applying portions of the Part 192 regulations to certain previously unregulated Class 1 gas gathering lines; and
• Applying federal reporting requirements to all gas gathering lines (whether regulated or not).
Gathering Line Definition
PHMSA is proposing to create a new definition for onshore gathering lines, as well as supplementary definitions for onshore production facilities or production operations, gas treatment facilities, and gas processing plants. While the text of the proposed amendments suggests PHMSA is seeking to codify many of the basic concepts embodied in the existing regulations, the NOPR would eliminate the reference to and depart from RP-80’s functional approach in at least two significant ways.
First, the proposed definition of “onshore production facility or onshore production operation” would start the gathering function at the furthermost downstream point of measurement for purposes of calculating mineral severance, or where the flow stream from two or more wells commingles. Under the current federal rules, RP-80 generally allows operators to extend the production function much farther downstream.
Second, it appears the proposed definition of “gathering line (onshore)” would restrict use of the incidental gathering designation to pipelines that do not leave property under the control of either the incidental gathering line operator or the operator of an adjacent pipeline where custody transfer takes place, or to pipelines that do not exceed one mile in length and that do not cross a state or federal highway or active railroad.
RP-80 does not impose any property, mileage, or crossing restrictions on using the incidental gathering line designation under the current federal rules.
If adopted as proposed, these changes could narrow substantially the scope of unregulated production operations, and would bring the range of potentially-regulated gathering operations to points much closer to the wellhead. Use of the incidental gathering line designation also could be restricted significantly, requiring operators to reclassify many of these lines as fully-regulated transmission lines.
New Safety Standards
PHMSA also is proposing to apply the federal pipeline safety standards to certain gas gathering lines in Class 1 locations. Specifically, the NOPR would partially repeal the exemption and apply a limited set of Part 192 safety standards to Class 1 gas gathering lines that have a maximum allowable operating pressure (MAOP) that produces a hoop stress of 20 percent or more of specified minimum yield strength for metallic lines, or more than 125 psig for nonmetallic lines that are at least eight inches in outside diameter.
Operators of these “Type A, Area 2” gathering lines would have to comply with the same safety standards that apply to lower-stress, “Type B” gathering lines. That includes implementing damage prevention and public awareness programs, establishing MAOP, installing line markers, conducting leak surveys for all lines, and providing corrosion control for metallic lines. The requirements for design, installation, construction, initial inspection, and initial testing would apply to any new, replaced, relocated, or otherwise changed lines.
To address a U.S. Government Accountability Office recommendation, operators of Type A, Area 2 gathering lines also would be required to comply with Part 192’s emergency response requirements. Finally, PHMSA is proposing to apply the federal reporting requirements to all gas gathering lines, including Class 1 gas gathering lines that do not meet the stresslevel and outside-diameter criteria to qualify as regulated, Type A, Area 2 lines. To comply with a statutory limitation in the federal Pipeline Safety Act, gathering line operators would not be required to submit any information to the National Pipeline Mapping System. PHMSA intends to use the information collected in these reports to determine whether additional gathering line regulations are necessary.
The deadline for submitting comments on the NOPR is June 7, although several pipeline industry trade organizations filed a request to extend that deadline. After the comment period closes, PHMSA must consider the information provided and present the NOPR to a federal pipeline safety advisory committee for consideration. The final step in the rule-making process would be issuance of a final rule containing new federal safety standards that have the force and effect of law.
