The Gas Gathering Rule (also known as the Mega Rule) is expected to affect midstream companies and gas gathering operators through the expansion of PHMSA jurisdiction, causing existing pipe to be regulated.
Some companies or operators may see a significant change in the percentage of their assets that become regulated by PHMSA when the Mega Rule comes into effect.
Why is this important? In addition to integrity management and other requirements for operating regulated pipe, the operation of the pipeline control center will become subject to the PHMSA Control Room Management Rule (CRM Rule).
This could lead to a necessary shift in resources to ensure alignment with the CRM Rule and prove compliance when subject to an audit. Before the Gas Gathering Rule takes effect, though, it is important to evaluate the timeline of events.
Timeline of the Gas Gathering Rule from 2017 to 2019
– In April 2017, PHMSA published a Notice of Proposed Rulemaking (NPRM) titled, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines.” The NPRM set out to accomplish the following:
- Propose the repeal of API RPI 80 for gathering lines and add a new definition for “production facility” or “production operation,” “gas treatment facility,” and “gas processing plant,” and a revised definition for “gathering line.” Note: This point has since been tabled.
- Extend regulatory safety requirements to Type A lines in Class 1 locations (with a diameter of 8.625-inches or greater).
- Extend the reporting requirements (incident and annual data) to all gathering lines.
- Requirements that would apply to previously unregulated pipelines meeting these criteria would be limited to damage prevention, corrosion control (for metallic pipe), public education program, maximum allowable operating pressure (MAOP) limits, line markers, and emergency planning.
The objective in 2017 was deciding on the expected timeline and evaluating the expected changes that would result from the new Gas Gathering Rule proposed by PHMSA. The goal was to determine whether an operator’s pipelines are regulated or not. And, if they are regulated, then deciding whether the CRM Rule applies.
– In January 2019, the Gas Pipeline Advisory Committee (GPAC) met to discuss the expected approach of PHMSA as it relates to Gas Gathering Rule. It was made clear that PHMSA would be moving toward additional regulation of pipe not previously subjected to the CRM Rule.
– On June 25 and 26 of this year, GPAC will resume discussions of the Gas Gathering Rule. The GPAC meeting is expected to result in the implementation of the rule this year. (Note: Read the follow-up article with the results from the committee meetings.)
Future Application of the Gas Gathering Rule
Based on recent GPAC presentations, it is expected that an expanded list of gas gathering pipeline types will fall under PHMSA jurisdiction. These assets will require CRM Rule compliance — 49 CFR Part 192 (Transportation of Natural and Other Gas By Pipeline) — to meet minimum federal safety standards.
The question for midstream companies and gas gathering operators is which type of pipeline is expected to come under PHMSA jurisdiction. These types are expected to become regulated under the Gas Gathering Rule:
- Type A, Area 1: unknown stress level
- Type A, Area 2: unknown stress level and MAOP exceeds 125 psig.
- Type A, Area 2: Class 1 location with 12.75 to 16-inch diameter pipe and with at least one dwelling in the Potential Impact Radius (PIR).
- Type A, Area 2: Class 1 location with a pipe diameter greater than 16 inches and no PIR limitations.
The classifications are expected to be discussed and potentially finalized during the June 2019 GPAC meetings as part of their final review of the rule. [Read the Latest Update]
For now, midstream and pipeline operators should be thinking about how much of their pipe could be newly regulated. This could affect advanced resource planning for compliance, audit, and regulatory purposes.
Contact EnerSys to Discuss Your Pipeline Assets
The EnerSys team is privileged to contribute to the GPAC meetings. If you have questions about how the new Gas Gathering Rule could affect your company or operation, contact us today to discuss your assets.
Additionally, take a moment to listen to EnerSys CEO Russel Treat’s recent update on the Gas Gathering Rule on the Pipeliners Podcast. You can also read the full transcript of his podcast episode for additional insight on the rulemaking process.