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In This Issue

  1. PHMSA Responds to Gas Gathering Rulemaking Petition for Reconsideration
  2. PHMSA Issues 2022 Civil Penalty Adjustments
  3. America’s Natural Gas Industry Will be Essential to Achieve a Net-Zero Emissions Future
  4. EFRD Evaluation
  5. Additions and Changes to PHMSA Forms for Gathering Pipeline Systems Annual Reports
  6. The Enforcement Corner
  7. Client Feedback

Additions and Changes to PHMSA Forms for Gathering Pipeline Systems Annual Reports

Type R (Reporting-Regulated) Gas Gathering Pipeline Systems Annual Report Form PHMSA F 7100.2-3 (new 3-2022):

Beginning approximately May 16th, 2022, PHMSA will now require annual reports for previously unregulated gas-gathering pipeline systems. The annual report will be documenting miles of reporting-regulated gas gathering lines by nominal pipe size (NPS), decade installed, material and corrosion prevention status, leaks eliminated or repaired by cause, and any known system leaks scheduled for repair, including those on federal land.

Changes to the Natural and Other Gas Transmission and Gathering Pipeline Systems Annual Report Form PHMSA F 7100.2-1 (rev 10-2021) are as follows:

Part B1 & T– HCA Miles by Determination Method and Risk Model Type

This is a new addition and will be deferred until 2023 when miles are reported for calendar year (CY) 2022. All miles are to be reported by HCA Determination Method 1 or 2, as well as the associated risk model, used for those pipeline systems.

Part D & P – Miles of Pipe by Material and Corrosion Prevention Status

Onshore Type C gathering miles is now an added option to the table where operators list miles by material, coating, and cathodic protection status.

Part I – Miles of Gathering Pipe by Nominal Pipe Size (NPS)

Onshore Type C miles have been added to the table for reporting gathering pipeline systems by nominal pipe size.

Part J – Miles of Pipe by Decade Installed

Onshore Type C gathering systems have been added to the table for reporting miles of pipe by the decade it was installed.

Part L – Miles of Pipe by Class Location

Onshore Type C gathering systems have been added to the table in which miles of pipe are to be reported by class location.

Part M1 – All Leaks Eliminated/Repaired in Calendar Year; Failures in HCA Segments in Calendar Year

This is where Onshore Type C gathering system leaks and failures eliminated, or repaired, in the calendar year will now be reported by cause.

Part M3 – Leaks on Federal Land or OCS Repaired or Scheduled for Repair

This is where Onshore Type C gathering system leaks repaired or scheduled for repair, on Federal Land or the OCS, are now to be reported.