In This Issue

Gas Gathering Final Rule

[Docket No. PHMSA-2011-0023]

PHMSA has provided an advanced copy of what will be the Final Rule for regulated gas gathering pipelines once published in the Federal Register (expected November 15, 2021).  The rule (Pipeline Safety: Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments) was originally included in the larger proposed “gas mega-rule”, but was subsequently separated so other elements within the mega-rule could be expedited due to congressional mandates.  Here is a summary of the key elements of the upcoming final rule.

  • The final rule requires operators of all onshore gas gathering lines to report incidents and file annual reports under part 191. Type R gathering lines are exempt from safety-related condition reporting requirements in §§ 191.23 and 191.25.  The final rule clarifies that all gathering lines are exempt from National Pipeline Mapping System submittals.
  • PHMSA is adding definitions under § 191.3 for “regulated onshore gathering” and “Reporting-regulated gathering.” The term “regulated onshore gathering” is defined as a Type A, Type B, or Type C gas gathering line as determined in accordance with § 192.8. The term “reporting-regulated gathering” is defined as an onshore gathering pipeline other than a regulated onshore gathering pipeline. These pipelines have been designated as “Type R” gathering lines in § 192.8 but are not regulated under that part.
  • The final rule adds a new paragraph § 192.8(b) to specify that gas gathering lines must maintain records documenting the methodology used to determine the beginning and endpoints of segments determined to be gas gathering lines as determined in accordance with part 192. This final rule specifies that these records must be established within 1 year of the effective date of the rule, or within 1 year of pipeline installation, whichever is later. These records include the API RP 80 definitions and methods used to define the beginning and endpoints and where those points are located (e.g., mile markers, address, or coordinates). Operators must maintain these records for the life of the pipeline, meaning until the pipeline is removed from the ground or permanently abandoned in place in accordance with § 192.727.
  • The final rule revises § 192.8(a)(5) to address the use of incidental gathering described in API RP 80. For new, replaced, relocated, or otherwise changed gas gathering lines installed after the effective date of this final rule, “incidental gathering” may not be used if the “incidental” endpoint is 10 miles or more from the furthermost downstream point where a gathering line endpoint is determined (e.g., processing facilities, compressor stations, points of comingling). A new, replaced, relocated, or otherwise changed pipeline that is designated as an “incidental gathering” pipeline but is 10 miles or more in length will be considered a transmission pipeline subject to all applicable portions of parts 191 and 192. Incidental gathering lines existing on or before the effective date of the rule may continue to operate as a gathering line, regardless of length.
  • The final rule provides for a new Type C regulated gathering line in § 192.8. Type C gathering lines are defined as gas gathering lines in Class 1 locations that have outer diameters of 8.625 inches or greater and operate at higher stress levels or pressures (i.e., metallic pipe with MAOP > 20% SMYS, metallic pipe with unknown stress levels and MAOP > 125 psig, and non-metallic with MAOP > 125 psig). The safety requirements for Type C lines include:
    • Design, installation, construction, and initial inspection and testing for lines that are new, replaced, relocated, or otherwise changed after the applicable compliance date in § 192.13 per transmission line requirements in part 192;
    • Corrosion Control (part 192, subpart I);
    • Damage Prevention Program (§ 192.614);
    • Emergency Plans (§ 192.615);
    • Public Awareness (§ 192.616);
    • Line Markers (§ 192.707); and
    • Leakage Surveys (§ 192.706).
    • Additional requirements for Type C gathering lines with outside diameters greater than 12.75 inches:
      • Applicable requirements of part 192 for plastic pipe and components; and
      • Establishment of MAOP (§ 192.619).
    • The applicability of each of these requirements is summarized in the table below:
Outside diameterNot located near a building intended for human occupancy or other impacted site (§ 192.9(f))Located near a building intended for human occupancy or other impacted site (§ 192.9(f))
Greater than or equal to 8.625 inches up to and including 12.75 inches-Design, Construction, Initial Inspection and Testing (new/replaced/relocated/changed lines)
-Damage Prevention,
-Emergency plans
-Design, Construction, Initial Inspection and Testing (new/replaced/relocated/changed lines)
-Corrosion Control
-Damage Prevention
-Emergency Plans
-Line Markers
-Public Awareness
-Leakage Surveys
Greater than 12.75 inches up to and including 16 inches-Design, Construction, Initial Inspection and Testing (new/replaced/relocated/changed lines)
-Damage Prevention
-Emergency Plans
All Type C Requirements
Greater than 16 inchesAll Type C RequirementsAll Type C Requirements
  • When determining whether the pipeline is located near a building intended for human occupancy or other impacted site, the final rule requires that operators of Type C gathering line use a factor of 0.73 for wet/rich natural gas in the PIR calculation rather than the 0.69 factor for dry natural gas used in the integrity management regulations. This results in a slightly larger potential impact circle reflecting the potentially more intense fire and explosion hazards due to the higher average energy content of unprocessed gas, which may contain higher concentrations of natural gas liquids and other hydrocarbons.
  • Operators must achieve compliance with applicable Type C requirements no later than 1 year after the effective date of the rule, unless PHMSA has approved an alternative compliance schedule after the operator has submitted a notification in accordance with § 192.18.
  • To address composite pipe, PHMSA has added a definition under § 192.3 and included a provision to allow operators to install or replace composite pipe that is not otherwise authorized by part 192 for use in regulated Type C gas gathering lines upon notification to PHMSA pursuant to §§ 192.9(h) and 192.18. Operators may use composite pipe or materials as proposed in their notification if, after 91 days, they have not received a letter from PHMSA with either an objection to the proposed use of composite pipe, or that states that PHMSA requires additional time to conduct its review. Additionally, operators may continue to use composite pipe installed on or before the effective date of the rule; no notification under §§ 192.9(h) and 192.18 would be required in those circumstances.

For a copy of this advanced copy of the final rule, or to inquire how RCP can assist with applicability of this rule and implementation requirements, contact Jessica Foley.