On July 17, 2013 Steve Pott made a presentation to the Colorado Oil and Gas Conservation Commission (COGCC) which touched on gas gathering and “Who Regulates Pipelines?” The Pipeline Safety Staff presentation included information on the Pipeline Certification Program and the cooperative agreement between PHMSA and the Colorado Public Utility Commissions (CPUC). Items to note from this presentation include:
- PHMSA regulates the safety of the inter/intra state hazardous liquid pipeline and the interstate natural gas pipelines in Colorado, while the intrastate gas pipelines are regulated by the PUC.
- CPUC updates their pipeline rules every 2 years.
- The presentation defined the pipelines the CPUC regulates and provided possible changes to the state regulations including:
- Prescriptive restrictions on state definitions
- Potential to classify “incidental gathering” as Type “B” in future rulemaking with operator waiver plan.
- Potential of adding requirements from 49 CFR 192.613 to ensure class location updates.
- Updating the definition of Type C pipelines to include pipelines operating at or above 20% of SMYS or nonmetallic pipelines operating at or above 125 pig.
The CPUC regulations have the following additional requirements for Type “B” Gathering pipelines in Class 2, 3, and 4 areas:
- Require instrumented leak survey
- Require reporting of “incidents” and “events” to the CPUC; and
- Require the preparation of a written procedural manual.
For a copy of this presentation contact Jessica Roger.