Midstream, gas transmission, and gas gathering operators were significantly impacted by the most-recent PHMSA GPAC committee meetings. During the meetings in June, the recommendation was made to include small diameter 8-inch pipelines with larger pipelines in the new Gas Gathering Rule.
The specific recommendation is that 8.625” diameter pipelines operating at 125 psi or above will be brought into this governance with certain requirements and a minimum standard of care.
This means even more pipe than was originally expected will be brought under federal jurisdiction to ensure compliance with the Control Room Management Rule (CRM Rule).
Now that operators are aware of the decision-making process, it’s time to prepare for how the Gas Gathering Rule will affect compliance in your operation.
Can You Account for Your Transmission and Gathering Lines?
The first step in the process of preparing for CRM Rule compliance is gathering documentation.
Do you have documents on-hand that capture the details of each pipeline that you own, manage, or are responsible for? Detailed information should include:
- Line size
- Operating pressure
- Location (High-Consequence Area or not?)
- Design and material (steel, composite, or plastic)
This is the baseline information you need to have readily available. After you collect and verify the information, you should also consider how you plan to gather a second layer of information.
The Gas Gathering Rule recommendation outlines a “minimum standard of care” that will eventually be required. Because of the amount of time and resources required to accurately gather information that meets this standard, the GPAC committee identified this element of compliance as a long-term goal.
However, it’s a good idea to start planning for how to gather these additional details about small diameter 8-inch pipe:
- Original and most recent inspections
- Corrosion control (for certain types of pipe)
- Line markers
- Leakage surveys
- Data on any incidents
- Damage prevention efforts
- Emergency response information
Next Step After Gathering Documentation
After gaining an understanding of what documentation is on-hand and what needs to be gathered, operators should assess the level of effort that will be required to fill the information gap.
Essentially, operators need to understand (a) how much pipe will be brought under federal jurisdiction and (b) how much effort will be required to gather documentation about each mile of pipe.
Make a record of your current standing to establish the starting point, communicate your starting point to internal stakeholders and decision-makers, and build a plan for how to gather the information.
There is another very important reason why this exercise is important. By having a clear understanding of your pipeline portfolio, you can plan in advance for necessary changes stemming from the Gas Gathering Rule.
Plan For How to Manage Newly Regulated Pipe
It’s one thing to have documentation of the new pipe that will be brought under federal jurisdiction. It’s another thing to have the resources and team to support compliance when the pipe is eventually subject to the CRM Rule.
Using the information you gather about your pipeline portfolio, you can make the internal case for more resources to help manage the change.
- Do you need to hire more staff?
- Do you need to purchase more consoles?
- Do you need more budget for training and development?
- Do you need additional software to ensure compliance with the CRM Rule?
By planning in advance for the Gas Gathering Rule, you can make the business case for more resources in your next budget plan. Don’t wait until it’s too late when the Gas Gathering Rule takes effect and you’re short on resources to support the change.
Take a proactive approach by alerting internal decision-makers about what’s changing, use the data you gathered about the newly-regulated pipelines to explain the situation, and build reports that capture the gap between current resources and future needs.
Support for Managing Newly-Regulated Pipelines
We understand this is a daunting task for many midstream, gas transmission, and gas gathering operators. It can be difficult to wrap your arms around how to gather the information and then how to build a plan to support compliance.
We are available to consult on the specific needs of your operation. We can perform an assessment of your pipeline portfolio to identify which assets are subject to new federal regulations and the applicability of the CRM Rule to your operation.
Also, because we attended the GPAC Committee meetings in June, we can provide a more detailed explanation of how operators will be affected by 8” pipe and other pipe becoming subject to federal oversight.