In This Issue

Final Rule on Gas Gathering Definition

Docket PHMSA-1998-4868

In a rulemaking that would make The Little Engine That Could proud, on March 15, 2006, PHMSA published its final rule on the definition of gas gathering lines. (The definition of gathering lines has been at issue since 1974.) This rule depends largely on API RP 80 to define the lines that are “gas gathering” with a few modifications. Of these lines, some are classified as “regulated onshore gathering” of either Type A or Type B.

The type is determined by population density around each pipeline and its operating pressure/stress level. Type A regulated onshore gathering lines are metal lines with a hoop stress of 20% SMYS or more, or non-metallic lines with an MAOP of more than 125 psi, in class 2, 3, or 4 areas. Type B lines are lines operating at lower pressures/stress levels than Type A lines in class 2, 3, or 4 areas. In addition, Type B lines in class 2 areas can be identified by one of 3 methods: the entire Class 2 area, oran area with more than 10 and fewer than 46 dwellings in a 1-mile-long rectangle extending 150’ on each side of the pipeline (“skinny class 2”), oran area with 5 or more dwellings in a 1,000-foot-long rectangle extending 150’ on each side of the pipeline (“skinny – short class 1 ½”)The amount of pipe that is regulated using methods 2 or 3 above can be reduced by truncating the area beyond 150’ from the last dwelling or cluster that causes the pipe to be jurisdictional. Note that no gathering lines in class 1 areas would be considered regulated onshore gathering, regardless of stress level or pressure. The old guidelines about residential and commercial areas, city limits, and so on, will no longer be used to identify jurisdictional gathering.

Type A regulated onshore gathering lines are required to comply with the transmission pipeline regulations, except for the requirements for making a line smart-piggable and for Pipeline Integrity Management. In addition, Type A lines in class 2 areas can meet their Operator Qualification obligations simply by describing their qualification process.

Type B lines are required to meet certain requirements for corrosion control, damage prevention, public education, line marking, and establishing the MAOP of the line. Any new, replaced, relocated, or otherwise changed lines will need to comply with current design, installation, construction, initial inspection and initial testing requirements.

The final rule takes effect April 14, 2006. Compliance dates for both Type A and B lines vary by topic and range from 10/15/2007 to 4/15/2009.

What does this mean? Operators of gas gathering pipelines will need to perform the following activities in response to this rule:

– Identify the pipelines meeting the current definition of “gas gathering.”
– Determine the operating stress level of metallic gas gathering lines and the maximum operating pressure of non-metallic lines.
– Conduct class location studies in order to determine the lines that are Type A and B regulated onshore gathering.
– Develop and implement compliance programs for all lines by the applicable deadlines.

Shameless commerce note: RCP has extensive experience with all of these activities, and we would be glad to assist your company as appropriate. We recommend that you start work quickly, as some of these activities can be time-consuming.

Contact Jessica Roger for additional information. You may also want to attend our special workshop on this topic on May 10, 2006 in Houston. (See the article above for details.)