On June 25 and 26, 2019, the PHMSA Gas Pipeline Advisory Committee (GPAC) met in Washington, D.C. to support PHMSA’s advance toward a final recommendation on the Gas Gathering Rule (rolled into the Mega Rule) to bring certain classifications of gas gathering lines under U.S. federal jurisdiction.
The purpose of the GPAC committee is to review PHMSA’s proposed regulatory initiatives to assure the technical feasibility, reasonableness, cost-effectiveness, and practicability of each proposal.
The committee also evaluates the cost-benefit analysis and risk assessment information of the proposals. Essentially, GPAC supports PHMSA in making meaningful improvements to pipeline safety as part of a continuous effort to drive toward the industry goal of zero incidents.
The topic of the most recent GPAC meeting was to make recommendations to PHMSA for their use in finalizing the gas gathering final rule. Specific discussions focused on:
- Definition of “gas gathering”
- Safety requirements for new regulated gas gathering pipelines
- Data reporting
EnerSys recently published a blog where we speculated on the outcome of the GPAC recommendations. By the end of the GPAC meetings in D.C., there were two expected results and one curveball.
– The two expected results were (a) recommending some level of data collection from all gathering pipelines and (b) the establishment of a reporting requirement (essentially, pressure records to establish a federal classification record of pipe relative to their MAOP).
– The curveball was the recommendation to include 8-inch pipelines in the Gas Gathering Rule.
When the original NPRM was published, the rule included pipe of 8.75 inches and greater in diameter located in rural areas. Through the comment period, revisions were proposed that some requirements would apply to 12.75 through 16 inches, and most requirements would only apply to gathering pipelines larger than 16 inches.
However, public representatives on the GPAC raised the question, “Shouldn’t there be a minimum standard even for 8-inch gathering pipelines?” GPAC discussions ultimately led to a recommendation that nominal, 8-inch pipe operated above 125 PSI should be incorporated into the Gas Gathering Rule as the rule is formalized and rolled out.
- October 1 Update: The new rule has now been published to the Federal Register.
Gas Gathering Rule Recommendation for Data Collection
The condition of data collection for gas gathering lines is very preliminary. If you were to make a comparison, data collection for transmission lines is mature, while data collection for gas gathering lines is in its infancy.
Therefore, the GPAC meetings focused on how to set minimum standards for gas gathering lines that are currently under federal jurisdiction and will be brought under federal jurisdiction.
The recommendation will be some level of data collection from all gathering pipelines. The rationale ties back to safety. PHMSA needs to know the nature of the lines in order to support the maintenance, improvement, and monitoring processes as part of gas safety systems.
The committee vote was nearly unanimous to include this requirement in the final rule, other than one objection on the specific wording about data collection. Overall, though, there was clear movement toward using data to help regulate gas gathering lines.
Gas Gathering Rule Recommendation for Reporting
The reporting requirement that will be included in the final Mega Rule also ties back to safety. PHMSA is taking into consideration that it must be practical to be implemented for different classifications of pipe.
Specifically, plastic pipe used in gas gathering lines has specific requirements compared to other types of materials such as steel and composite.
There was a recommendation to add a Class C classification to make this differentiation and there was discussion about how to classify lines based on MAOP.
Another complication is newer lines. “What if you don’t have 5 years of pressure records to know what your actual pressure allowance is?”
GPAC recognized the need to allow for time to submit records on each section of pipe operated by a gas gatherer. The suggestion was to include a “no objection policy” where an operator can submit their records and if they do not hear back from PHMSA with an objection, then that qualifies as acceptable.
This conversation about newer pipe versus existing pipe also led to a discussion of the difference between new construction versus repair. The result was further encouragement from the committee to include the no objection policy in the MAOP determination. It’s a complicated topic. The end result was a unanimous vote to allow for a period of time in the reporting requirement for gas gathering operators.
Gas Gathering Rule Recommendation for Additional Pipelines Included
Now for the curveball of expanding the Gas Gathering Rule to include 8-inch pipe and larger.
Again, going back to the overall theme of safety, there were specific discussions about establishing base considerations around:
- Line size
- Line operating pressure
- Location (HCAs or not)
- Design and material (steel, composite, and plastic)
The purpose was to look at the impact on human safety. This set the tone for a discussion of why certain size pipe was not included in the rule.
The previous recommendation was for pipe 12.75” to 16” with at least one dwelling in the Potential Impact Radius (PIR) and pipe 16” and larger with no PIR limitations to be included.
However, the concern was brought up that pressure could still be an issue in pipe no matter the size of the pipe or the location. The public interest represented at the GPAC meetings wanted a minimum standard for 8-inch gathering lines operating at 125 PSI.
After discussion, a recommendation was made to move forward with the idea that 8.625″ lines will be brought into this governance with different requirements and a minimum standard of care.
What will be included in this “minimum standard?” Design, installation, construction, and initial inspection for awareness, line markers, leakage surveys, damage prevention, and emergency response.
The challenge for leakage surveys is the cost requirement. The long-term goal is to slowly move toward implementation for smaller lines, recognizing that operators cannot flip the switch on this in the immediate future.
However, the bottom line result is that nominal, 8-inch pipe operated above 125 psi will be incorporated into the gathering rule when it’s formalized and rolled out. In the future, there will be added details on how this will be formalized.
Takeaways for Gas Gathering Operators
The GPAC committee meetings certainly moved the ball down the field toward finalizing the Mega Rule for gas gathering operators. To see the final scope of newly regulated gas gathering lines, watch the last video in the presentation slides available on the PHMSA website.
The question for operators moving forward is what a minimum set of requirements will look like, especially the base floor for operators running 8-inch pipelines at higher pressures.
Fortunately, there is a long runway to get ramped up for leak surveying, data collection, and reporting requirements. PHMSA is also planning to allow time for the vendor community to look into the latest technology available to support gas gatherers and expedite the process.
At the end of the day, safety is the central focus for industry. Everything that was discussed in D.C. tied back to safe operations, which is everyone’s goal to achieve business goals with no harm.
For gas gathering operators, stay connected to EnerSys to remain in the loop about the next steps leading to the Mega Rule implementation. Subscribe to our eNews (scroll down to the very bottom of this webpage) for further updates and information.