In late 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new final Gas Gathering Rule bringing 400,000+ miles of pipeline assets under federal jurisdiction.
In this blog, we will take a high-level look at the new regulation contained in the PHMSA Gas Gathering Rule and present information on how the rule might affect you as an operator of gas gathering lines.
PHMSA Gas Gathering Rule: Overview of New Regulation
The final rule, which had been in discussion for a decade, adds reporting requirements and expands on the definition of regulated gas gathering lines to include pipelines (Type C) that were previously exempt from Federal reporting requirements.
According to PHMSA, the purpose of the new regulation is to help gather data about the state of gas gathering infrastructure and to monitor the safety performance of gas gathering lines that were previously exempt from Federal reporting requirements. The purpose of the final rule is designed to achieve the following objectives:
- Prevent and detect threats to pipeline integrity.
- Improve public awareness of pipeline safety.
- Improve emergency response to pipeline incidents.
Understanding New Type C Gathering Lines
As an operator of gas gathering lines, you need to review the distinct definitions of Type A, B, and C gathering lines to understand the baseline requirements. This will also provide you with a greater understanding of how this new rule affects you. Let’s review the new Type C classification:
- Type C gas gathering line definition – according to PHMSA: gas gathering lines in Class 1 locations (e.g. rural locations) that have outer diameters of 8.625 inches or greater and operate at higher stress levels or pressures.
PHMSA is seeking to minimize the potential consequences of incidents involving larger diameter, higher-pressure pipelines in Class 1 locations in addition to those gathering lines that are already regulated in Class 2, 3, 4 locations.
As a result, Type C gathering lines with larger diameters (>16”) that are near homes and buildings are required to comply with the requirements for Type B gas gathering lines that are already in place. Operators of these Type C lines also must develop and implement emergency plans.
The remaining Type C gathering lines with smaller diameters (8.625” > 16”) or in locations that are not expected to directly affect homes and buildings will have fewer requirements that are limited to damage prevention, emergency plans, and public awareness.
Impact of PHMSA Gas Gathering Rule on Operators
As you look at the new rule, you will need to understand the degree of impact it will have on your operations. The level of impact will be directly related to the miles of Type C lines you operate, the diameters and pressures under which they operate, and what you are currently doing to comply with the existing regulations.
Then, you need to ask yourself the following questions:
- Do these new requirements severely impact my operations because I only operate Type C miles? As a result, will I have to implement programs that are new?
- Do these new requirements minimally impact my operations because I only operate Type C lines that are under 16”, and I have Type B programs in place?
- Or, is my operation somewhere in between?
Once your impact is determined, the next question to be answered is: Do I need to expand my current damage prevention, emergency planning, and public awareness programs, enhance them, or do I need to create them from scratch? Let’s review your response.
Support Public Awareness and Emergency Response
Developing public awareness programs and supporting emergency response is part of an effective Pipeline Safety Management System (Pipeline SMS, API 1173). Pipeline SMS is a systematic approach to applying quality management principles to pipeline operations, which results in operators supporting the safety objectives outlined by PHMSA.
The Pipeline SMS framework contains 10 core elements. Two of which are the following:
- Stakeholder Engagement includes public awareness programs.
- Emergency Preparedness and Response includes the involvement of emergency planners to support emergency plans.
Whether you are starting from scratch with public awareness programs for your gathering lines, or looking to expand and become more effective, we recommend utilizing a technology-driven, digital approach to create awareness and engagement with affected stakeholders.
– Instead of handing out mailers to residents or business owners in the areas where you operate federally-regulated gathering lines, you can use technology to communicate, build dialogue, track responses, and feed information back into your safety programs.
– To support damage prevention, operators should use technology to engage excavators and other stakeholders around your ongoing activity and any special projects. This way, you can readily share information, help stakeholders know where to find pertinent details, and provide an avenue for stakeholders to report anything they find.
– Additionally, you should engage emergency support personnel in the area of your gathering lines. Use technology to make them aware of what you’re doing, operating, and running. Help them know where your Type A, B, and C gathering lines are located.
Make sure you have a plan in place for how to communicate this information and provide emergency teams with a way to get in contact with your operation if there is an incident. If you already have a plan, then update it to include newly-regulated pipe. If you don’t have a plan, then you need to write one and communicate it appropriately.
We Can Help With Implementation of the Gas Gathering Rule
Each pipeline operator will have unique requirements based on their current operating environment. Our software suite of process management and stakeholder engagement tools can facilitate compliance to the new regulations, regardless of where you fall on the impact scale.
- Through our ICAM software tool: help you manage, schedule, track, document, and report the execution of your programs in compliance with PHMSA requirements.
- Through our pSEc tool: help you communicate and exchange information with stakeholders, track the responses, and feed information back into your programs.
By working with our team, we’ll help you gain confidence that your gathering lines are aligned with the new PHMSA requirements and that you continue to operate safely and efficiently. And, if you have questions about the classifications of gathering lines, we can review your current assets to help you make a determination.
– Contact us today to schedule a consultation about how we can support your operation through our software and expertise. Let us help you align with the new regulations in the PHMSA Gas Gathering Rule.
