In This Issue

RCP Services Spotlight — Gas Gathering Jurisdictional Determination

On March 15, 2006, PHMSA published its final rule on the definition of gas gathering lines. 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.

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.

RCP is in the process of helping gas production, gathering and transmission pipeline operators update their jurisdictional determinations for these lines.

If you are interested in how RCP can help you evaluate the jurisdictional classification of your pipelines, give Jessica Roger a call at (713) 655-8080.