Mega Rule Part 3: Onshore Gathering Lines

headshot of Andy LawtonAuthor: 
Andrew Lawton | Principal/Program Director, Utilities | andrew.lawton@pondco.com



 

For the first time ever, the Pipeline and Hazardous Safety Administration (PHMSA) has expanded certain federal regulations to all onshore gas gathering pipelines, regardless of size or location. This final rule extends reporting requirements to more than 400,000 miles of previously unregulated gathering lines. PHMSA expects the final rule will improve public safety, reduce integrity threats and promote environmental justice. Part 3 of the final rule expands regulations in four ways: 

  • Reporting Requirements 
  • Gathering Line Definitions 
  • Expanded Scope of Gas Gathering Line Regulations 
  • Safety Requirements for Newly Regulated Lines 
Reporting Requirements 

PHMSA issued regulations in 2006 when conventional, vertical wells were being used in gas gathering lines. However, since 2006, industry technology has allowed operators to drill horizontal wells to access shale plays. This increased volume in natural gas led to the natural evolution of large diameter, high-pressure gathering lines. These gathering lines have the same functional and operational characteristics as transmission pipelines but are not subject to the same regulations. Now, PHMSA is expanding regulations to all onshore gas gathering lines, meaning that operators are subject to incident and annual reporting under part 191. In addition to extending reporting requirements, PHMSA introduced two new designations for gathering lines: Type “C” and Type “R”. 

Type C gathering lines are defined as gas gathering lines in Class 1 locations that have an outside diameter =8.625 inches and any of the following:  

  • Metallic and the MAOP produces a hoop stress of =20% of SMYS 
  • Unknown stress level, metallic and the MAOP >125 psig (862 kPa) 
  • Non-metallic and the MAOP is more than 125 psig (862 kPa) 

All other lines that meet the gathering line definition but do not fall into Types A, B or C will be designated as Type R. The only requirements for Type R lines are incident and annual reporting. Based on this data, PHMSA will determine the need for and scope of future regulation.  

Gathering Line Definitions 

The existing definitions for gathering lines borrow language from the American Petroleum Institute Recommended Practices 80 (API RP 80), but in practice, operators and inspectors have had trouble consistently applying these definitions. PHMSA proposed to revise 49 CFR part 192 to clarify the definition of gathering lines and provide stand-alone definitions for related processes. Several organizations opposed these revised changes citing potentially ambiguous language and a violation of PHMSA statute of limitations on regulating production lines. API also opposed these changes but suggested edits that would provide more specificity to processes that could be considered functions of production. In addition to these edits, AIP RP 1182 has since been published which focuses on safety provisions for large diameter gather lines and some aspects have been adopted into the final rule. 

The final rule also imposes limits on the concept of “incidental gathering” on new, replaced, relocated, or otherwise changed gathering lines. A clear and defined limitation of ten miles will be applied to any pipelines constructed after the final rule’s effective date of May 16, 2022. Therefore, the “incidental gathering” concept may not be applied to a newly constructed pipeline measuring ten or more miles long. This new ruling will help close the gap that prevented pipelines whose functions were operationally indistinguishable from transmission lines from being regulated as such.  

Expanded Scope of Gas Gathering Line Regulations 

The newly designated Type C gathering lines must comply with a basic set of requirements described in § 192.9. The specific requirements for newly regulated gas gathering lines are outlined below: 

Given PHMSA’s prompt six-month compliance deadline, the final rule includes procedures for an operator to request an alternative compliance deadline with a notification in advanced writing. 

Safety Requirements for Newly Regulated Lines 

The table below highlights the specific safety requirements for newly regulated Type C gathering lines. 

What We Do 

Pond provides full-service consulting for Mega Rule compliance including design, risk assessments, corrosion controls, direct assessment, turn-key ILI services, and field services. Our team of experts works with operators to meet the regulatory requirements that ensure public safety, environmental protection, and responsible asset management. For more information about Pond’s Mega Rule compliance services, click here. 

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