I was privileged to have attended the PHMSA June 25-26, 2019 Gas Pipeline Advisory Committee (GPAC) meeting in Washington, D.C. to hear discussions on the proposed rules regarding Gas Gathering Lines. These proposed rules were part of the April 2016 Notice of Proposed Rule Making (NPRM) titled “Safety of Gas Transmission and Gathering Pipelines.” Having served on the GPAC from 2016-2018, I attended all previous meetings related to this mega-rule as an active voting member. Even though I was just an observer in the audience at last week’s meeting, I still felt a great sense of pride in knowing that this was the final GPAC meeting on the mega-rule, that Pipeline Safety in the United States had been advanced, and that I played a small role in helping the GPAC across the finish line.
A gathering line is defined as: “… a pipeline that transports gas from a current production facility to a transmission line or main” (49 CFR §192.3).
Gathering operations have historically consisted of primarily small-diameter, low-pressure pipelines that supported conventional wells. With advanced drilling technologies, such as horizontal drilling and hydraulic fracturing, there have been substantial increases in the production of natural gas. This increased production led to the construction of additional gathering lines, many being large-diameter pipe operated at significantly higher pressures. These new gathering lines have taken on operating characteristics and hazards similar to high-pressure cross-country transmission lines.
The primary concern is that because of their rural location and how the existing pipeline safety regulations are written, many of these large, high-pressure gas gathering lines are currently exempt from regulation. The bottom line: these gathering lines bring with them higher risks, increased safety concerns and the need for a practical, risk-based regulatory solution.
To put this into perspective, there are currently around 450,000 miles of gas gathering lines in the United States. PHMSA only regulates about 18,000 miles of these in total, with 11,650 miles of this being onshore. It is important to point out that not all gas gathering lines present the same level of risk and therefore, extending comprehensive regulation to “all” of these lines is not reasonable, cost effective, nor practicable (i.e. doable or feasible). The vast majority of gathering lines (79%) are less than 8.625” in diameter, operate at lower pressures, and are located within unpopulated areas. This rulemaking is the beginning of the journey to enhance safety, and as such, focuses on high-stress gathering lines greater than 8.625”.
In the Pipeline Safety Act of 2011, Congress mandated that the DOT review existing gathering line regulations and provide a report to Congress addressing the sufficiency of existing regulations and the impact of applying existing Federal regulations to gathering lines currently exempt from regulations. PHMSA completed this review and concluded that additional regulations were needed to address the risks associated with gathering lines. They specifically concluded that additional data was needed to more effectively assess the risks associated with the nation’s gathering lines so that appropriate regulations could be advanced.
PHMSA developed the ensuing NPRM to include recommendations regarding the following four topics which were to be voted on:
o Requiring operators to report all incidents as well as annual pipeline data
o Requiring all gathering line operators to obtain an Operator Identification Number using the National Registry
Definitions & End Points of Gas Gathering:
o Repealing API RP 80 (which is currently incorporated by reference into code and provides a functional description of onshore gas gathering pipelines), and replacing it with new definitions for gathering lines, and other production and processing facilities
o Design, installation, construction, and inspection
o Corrosion control
o Damage prevention
o Public awareness
o Line markers
o Leakage surveys and repairs
o Emergency plans
Scope of Newly Regulated Gas Gathering:
o Extending current regulation to higher risk lines in Class 1 (Rural) locations with diameters of 8.625-inches or greater
As part of the rulemaking process, PHMSA solicited public comments. PHMSA received approximately 200 comments from a variety of stakeholders including those from industry operators, industry service providers, industry trade associations, government, and public advocacy groups. Commenter positions ranged from being in total support for new regulations to total opposition of new regulations. Comments received included detailed aspects or concerns regarding the proposed rule, along with recommendations offered by stakeholders to address those concerns.
During the day and a half meeting, PHMSA led the Committee through a slide deck of approximately 140 slides. The meeting was webcast and recorded. It can be viewed at the following link: https://www.phmsa.dot.gov/standards-rulemaking/pipeline/pipeline-gpac-webcasts .
The detailed review of each of the four areas to be voted on by the Committee followed a structured process and included:
– A review of the various aspects of each proposal
– A review of public comments and PHMSA’s responses to these comments
– PHMSA suggestions for the Committee to consider
– Public comments (from the audience – both onsite and online
– GPAC Discussion
– Review and modification (if needed) of proposed voting slides
– Committee vote
Need for Additional Data
In my opinion, there are several takeaways from last week’s GPAC meeting. I feel the acknowledgement by PHMSA and the affirmative voting by the GPAC members to require additional reporting is just the first step in the journey of bringing currently exempt or unregulated gathering lines under regulation. Since we are dealing with previously exempt facilities, we don’t know what we don’t know. Additionaldata obtained through annual and incident reporting requirements will ultimately be used to inform future rule making regarding how best to regulate gathering lines.
Withdrawal of Repeal of API RP 80
Another takeaway was that PHMSA and the Committee agreed the repeal of API RP 80 was not appropriate at this time. Significant efforts are underway by the API RP 80 Working Group to consider revisions to the recommended practice regarding “Guidelines for the Definition of Onshore Gas Gathering Lines,” and the development of API RP 1182 “Risk Assessment for Larger Diameter Gas Gathering Lines or Safety Provisions for Onshore Gas Gathering Lines.” PHMSA will be monitoring the efforts of this Working Group and will keep the Committee apprised. There is more to come.
Extending Regulation to Higher Risk Gathering Lines
The original NPRM included extending regulations to higher risk lines in Class 1 (Rural) locations with diameters of 8.625” or greater. PHMSA changed its proposal to include only lines greater than 12.75” through 16” with at least one building for human occupancy or “other impacted sites” in the Potential Impact Radius (PIR), and all lines greater than 16”. Ultimately, the Committee voted on language that set minimum requirements (e.g. damage prevention; line markers; public awareness; leak surveys and repairs; emergency plans; design, installation, construction, and inspection and testing for new lines) for gathering lines 8.625” in diameter and greater.
Individual Committee Member Comments
Lastly, there were a few comments made by various Committee members I feel are worth repeating.
“If it looks like a duck, walks like a duck and quacks like a duck, it is probably a duck.” This was in reference to the notion that if a gathering line has all the characteristics of a transmission line then it should be regulated in a similar manner.
“Since we are entering the unknown, we must be pragmatic about the direction of gathering line regulations and be cautious of the potential for unintended consequences.”
“Interrogate the data until it confesses.” In other words, be thorough with our analyses.
“It is our collective goal to advance safety. This is a journey!”
“We have primary, secondary and tertiary concerns… We need the data to decide where to start.”
“PHMSA must be clear on the expectations set in the wording of the final rule.”
To wrap it up, I am very pleased with where PHMSA and the GPAC ended up last week with the Gas Gathering line rule. I feel the guidance and feedback the Committee provided to PHMSA was thoughtful and insightful, and accurately represented the views and concerns of the various stakeholders affected by this rule. As I said at the beginning of this post, pipeline safety in the United States was advanced last week. The journey has begun in subjecting previously exempt gathering facilities to common sense regulation.
Executive Director, Pipeline Safety