Pipeliners Podcast host Russel Treat returns from Washington, D.C. with a timely update on the Gas Gathering Rule (Mega Rule).
Listen for an important recap of the discussions during the PHMSA GPAC Meetings that advanced the Mega Rule toward final rulemaking. Included were two expected results on data collection from all gathering pipelines and the establishment of a reporting requirement. Also included was a curveball to include 8” pipelines in the final rule.
What does all of this mean for gas gathering operators? Listen for the key takeaways from the GPAC Meetings that will affect pipeliners moving forward.
- NEWLY ADDED 7/15: Download the GPAC voting slides from the Gas Gathering meeting.
PHMSA GPAC Meeting Update & Mega Rule: Show Notes, Links, and Insider Terms
- PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
- Howard “Skip” Elliott is the fifth Administrator of PHMSA. Elliott joined PHMSA after retiring from CSX Transportation in Jacksonville, Florida, where he served as Vice President of Public Safety, Health, Environment, and Security.
- The Gas Gathering Rule (Safety of Gas Transmission and Gathering Pipelines) was initiated in 2016 when PHMSA issued a notice seeking comments on changes to the pipeline safety regulations for gas transmission and gathering pipelines. The proposed rule has advanced through various stages to expected issuance in 2019.
- GPAC (Gas Pipeline Advisory Committee) is organized by PHMSA to review their proposed regulatory initiatives to assure the technical feasibility, reasonableness, cost-effectiveness, and practicability of each proposal.
- The Pipeline Safety Trust (PST) is a public charity promoting pipeline safety through education and advocacy by increasing access to information, and by building partnerships with residents, safety advocates, government, and industry.
- Carl Weimer is the executive director of the PST.
- GPA (Gas Processors Association a/k/a GPA Midstream) is an advocacy organization for the midstream industry that is focused on enhancing the viability of natural gas, natural gas liquids, and crude.
- API (American Petroleum Institute) is the only national trade association representing all facets of the oil and natural gas industry, which supports 10.3 million U.S. jobs and nearly 8 percent of the U.S. economy.
- API RP 80 sets the guidelines for the definition of onshore gas gathering lines.
- API RP 1182 was introduced to address the emergence of larger diameter, higher pressure gas gathering lines used in Shale environments.
- The Texas Pipeline Association is the largest and only state trade association in the U.S. that represents solely the interests of the intrastate pipeline network in Texas.
- Read TPA’s research and best practices one-pagers: Why Should Pipeliners Matter To You? and Eminent Domain Authority.
- MAOP (maximum allowable operating pressure) was included in a bulletin issued by PHSMA informing owners and operators of gas transmission pipelines that if the pipeline pressure exceeds MAOP plus the build-up allowed for operation of pressure-limiting or control devices, the owner or operator must report the exceedance to PHMSA on or before the fifth day following the date on which the exceedance occurs. If the pipeline is subject to the regulatory authority of one of PHMSA’s State Pipeline Safety Partners, the exceedance must also be reported to the applicable state agency.
- Gathering Line types include Type A and Type B.
- Type A: Metallic and the MAOP is more than 20% of SYMS, or non-metallic and MAOP is more than 125 psig.
- Type B: Metallic and the MAOP is less than 20% of SYMS, or non-metallic and MAOP is less than 125 psig.
- Class location is an onshore area that extends 220 yards on either side of any continuous 1 mile of pipeline. Also, each unit in a multi-unit building is counted as a separate building. [View this detailed presentation on how to determine class location.]
- Class 1: Offshore, or has 10 or fewer buildings for human occupancy (e.g., rural).
- Class 2: More than 10 buildings, but less than 46.
- Class 3: More than 46 buildings; or an area where the pipeline lies within 100 yards of a place where people gather (20 or more people, at least 5 days a week for 10 weeks in any 12 month period).
- Class 4: Buildings with 4 or more stories above ground are prevalent.
- PIR (Potential Impact Radius) is defined by PHMSA (49 CFR subpart 192.903) as the radius of a circle within which the potential failure of a pipeline could have significant impact on people or property.
- MPMS is an advanced geomapping tool used to identify the specific location of critical infrastructure and physical assets such as pipelines.
PHMSA GPAC Meeting Update & Mega Rule: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 83, sponsored by Gas Certification Institute, providing training and standard operating procedures for custody transfer and measurement professionals. Find out more about GCI at gascertification.com.
Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.
Russel: Thanks for listening to the Pipeliners Podcast. We appreciate you taking the time. To show that appreciation, we are giving away a customized YETI tumbler to one listener each episode. This week, our winner is Erin McKay of Harvest Midstream, Alaska. Congratulations, Erin, your YETI is on its way. To learn how you can win this signature prize pack, stick around until the end of the episode.
This week, I am sitting in the airport in a little private space. You may hear some background noise, and if so, I apologize for that. But I wanted to get this episode out promptly.
I spent the last couple of days attending the gas pipeline advisory committee meetings with PHMSA in Washington, D.C., where they were discussing and voting on recommendations to PHMSA regarding the Gas Gathering Rule. It was a very interesting session, or at least I thought so.
Before we dive into it, let me try and do a brief summary of this Gas Gathering Rule. The Gas Gathering Rule is a section or a segment of what many people have called the Gas Mega Rule. It’s the last piece to kind of get rolled up and finalized through the GPAC review process.
For those who don’t know what GPAC is, it’s the Gas Pipeline Advisory Council. It’s a committee that is chartered by Congress to provide advice to PHMSA. They conduct meetings and review recommended rulemaking and provide advice to PHMSA regarding that rulemaking.
The committee consists of a number of different stakeholders, and there’s multiple people on the committee from each of the stakeholder committees. One of the stakeholder groups would be industry, those companies, entities actually operating pipelines. Another stakeholder group would be the public, so organizations like the Pipeline Safety Trust that would represent public interest.
Then you have other members of government, so state and local government that are interested in pipeline regulations and are stakeholders in pipeline regulations for obvious reasons.
The process is all on the record. It’s all formal. The point is to get to the point they can make a recommendation that PHMSA can take away and use to finalize a rule.
The number of areas covered, one was definition of gas gathering. Another was safety requirements for the lines. The other was data reporting.
One of the primary things that the industry advocates for in any rulemaking like this is that the rulemaking be practicable and move or improve pipeline safety. Practicable, meaning that it can be implemented at a reasonable cost with current technology, using current levels of resourcing.
That’s probably a bit of an overstatement, but the idea is it has to be something that can be done. You can’t ask a company to do something that you can’t actually accomplish, you can’t actually do. The whole idea of the process is to allow the public to advocate what they think is in the public interest, and allow industry to advocate for what they think are reasonable steps.
I think one of the big things that’s important to understand about GPAC and about these committee meetings, and I’ve seen this in the past, is that GPAC is really — and this is universal for all the stakeholders — they’re very interested in making meaningful improvements in pipeline safety, and make that a continuing and ongoing effort. This is a process that isn’t going to stop I guess would be one way to think about that.
The meeting started off with some remarks by Skip Elliott, the PHMSA administrator. There was basically recognition for the good work and recognition about gathering, particularly gathering in the Shale space, where the sizes and pressures of some of the gas pipelines look a lot more like transmission lines than they do like gathering lines.
A big part of the direction given to PHMSA was move forward in a way that addresses these larger higher pressure gathering lines and addresses them appropriately. Gathering and transmission are different, the way those companies operate, what they’re trying to do. They’re different, so there’s unique considerations.
As the committee is going through its work and its conversations, it’s all supported by presentations that have been developed in advance by PHMSA. We’ll make those available. We’ll link them up on the website. If you have an interest in grabbing that content, you can.
The tee-up was really about what’s driving this and the general recommendations that PHMSA is making. They talked about this particular committee meeting is specific to gas gathering. There are base considerations, and those base considerations have to do with line size, line operating pressure, the location, whether or not it’s in a high consequence area, and the design and materials.
One of the things that’s unique is in gathering, you find steel, composite, and plastic pipe, all used in gathering. You don’t find that in transmission, typically, and particularly not composite. You don’t find composite at all. There are some special considerations, if you will, around gathering.
The purpose being to look at the impact on human safety. There was some talk about, “What is that?” There’s a table that’s on Chart 6 of the presentation that talks about Type A, area one, Type B. It’s trying to classify or create some structure around what the things will be, what things will be considered in terms of pipe, pipe size, and so forth.
The first conversation was around data reporting. The way that the committee kind of works, they tee up a topic. PHMSA will make a presentation to get information on the record about that topic. It’ll include any research they’ve done, any public comment that’s been received and processed. Basically, it’s there to get everybody that’s on the committee up to speed as to current state.
Then they’ll open it up for public comment. This was the first time they actually webcasted one of these GPAC meetings.
A couple things I think are interesting about this, or important for industry to understand is that the Pipeline Safety Trust and Carl Weimer put some comment on the record specifically talking about data gathering. That’s the first topic that was discussed, was a concern about reporting pipelines at what counties they exist in, versus the specific locations, a concern that the idea of putting gathering lines into MPMS is off the table, and some disappointment that some specific mapping information about locations.
His point being that first responders and such should have an idea of where these pipelines actually exist. Matt Hite, who is with GPA, made comments on behalf of GPA. GPA is the Gas Processors Association. It’s the Midstream Gas Operators, and it’s the people most impacted by this particular rulemaking.
There was a lot of support for keeping API recommended practice 80 in the standard and not pulling it out, because they felt it would create confusion about what is and what is not classified as gathering. There was a lot of conversation about supporting the PIR process. That’s impact radius. If I have an issue, impact radius can be calculated, based on the size of the pipeline and the pressure operating the pipeline.
The president of the Texas Pipeline Association made the comment that they had long advocated data collection on gathering lines, and that the data collection shouldn’t be more stringent or more data collection than what’s currently done transmission. Also, kind of an interesting conversation, because data collection for transmission is a fairly mature process.
Data collection for gathering is a brand new process. There’s a lot of conversation around these topics. I’m going to try to summarize it. [laughs] I’ve got like 14 pages of notes from a day-and-a-half of meetings. It doesn’t make sense to try and go through all of it. I think what most people are interested in is, “Where did it land?”
Kind of the bottom line on this topic is that where this rule is headed is they’re going to recommend some level of data collection for all gathering pipelines.
PHMSA did work. They estimate there’s about 400,000 miles of gas pipeline in the United States that’s classified as gas gathering. About 90,000 miles are eight inches or larger, so kind of interesting. But, the data collection initiative is on all pipelines.
The rationale here is that some level of data collection is necessary to understand what is the nature of those lines, what’s the nature of the public impact, and what kind of actions would be appropriate and practical for improving safety of gas gathering systems. There’s a lot of conversations in this about recommended practice 80.
You may not know, but API has a working group, working on RPA, which is the rule around how gathering is determined. There has been a big effort to get that updated. One of the co-chairs of that committee was asked when do you think this is going to get done? That answer was that they hoped to have a document out ready for review and ballot by end of year, so that’s a pretty material thing.
There’s also recommended practice 1182. I’m not going to talk about that, because I don’t know a lot about it. It came up several times, but I’m not familiar with 1182. It’s related to classification of pipelines and for gathering in classified areas, and so forth.
Kind of the bottom line, when they got this all put together, there were a lot of clarifying questions about what data should be collected. There was specific guidance given on this topic to PHMSA. The bottom line is the vote was unanimous with the exception of one abstention, recommending some wording that in effect says, yes, we need to collect this data so that we can determine what the state is and make decisions about what future actions might occur.
Throughout the meeting as well, there was a lot of conversation about being very clear in the preamble. This rulemaking that this move towards further regulation in gathering, it’s not a one-and-done kind of thing. It’s a first step in a process to focus on improving pipeline safety.
The next conversation was about the safety requirements. What safety requirements are going to be placed on gathering lines? The president of the plastic pipe institute put some commentary on the record, basically asking that plastic pipe be looked at, and if the rules, particularly the integrity management rules be looked at as they relate to plastic pipe.
The implication to any of that is it’s going to be different. One of our former Pipeliner Podcast guests got up, made a recommendation that PHMSA create a Type C, versus a Type A that makes it easier to understand what pipe does this rule apply to.
There was a commentary or input from The Association of Plumbers and Pipefitters. Their recommendation is that all pipeline should be installed with proper materials and methods, and with management of corrosion regardless of size or operating pressure, and that welder qualification requirements should apply to all pipelines the way they are applicable to transmission.
This is a complicated issue. I’m not going to try to unpack it completely, here. But, there is discussion about how these lines get classified, given how you classify MAOP and the various approaches to do that. What do you do if you don’t have five years of pressure recording records to be able to make a basis of determination as to your MAOP?
I would generally contextualize that conversation as operators should be allowed to make submissions and present a basis for those submissions, and that there should be a no objection provision. If once I submit a pipeline, I submit its MAOP, if I don’t hear back that it’s unacceptable, then I can assume it’s acceptable. That’s called a no objection policy. I thought that was interesting.
There was a lot of conversation about this, about welding requirements, how are they different. There was a lot of conversation around new pipe, versus existing pipe, and what is appropriate for new construction, versus what’s appropriate for existing construction. There was also a lot of conversation around what is the difference between new construction and repair, and how does that impact things.
There was encouragement from the committee to include a no objection process to the MAOP determination, clarify the welder qualification requirement on new, replaced, relocated, repaired pipe, what that looks like. Ultimately, the committee got this down to a voting slide in the presentation. This particular thing went down as unanimous.
All of that, to my mind, was pretty much as it was expected. What wasn’t expected was this…
If you’ve listened to previous podcasts or if you’ve gone to my LinkedIn page and read the article I recently wrote, you’ll see where it talks about the recommendation that this new rule be applied to lines greater than 12.75 inches with different requirements for 12.75 to 16, versus larger than 16.
Here’s where it got interesting. One of the public representatives made the comment that when the first analysis was done, it took into consideration that eight-inch lines should be gathered into the regulation just like 12.75. There was a whole lot of conversation about the impact of pressure and line size, and what the impact area would be if there was an incident, and how does that impact public safety, and how does that deal with methods that are used in transmission, and what would be the difficulties and problems.
The public took a pretty strong position that some minimum standards should be applied to these eight-inch lines operating over 125 PSI pressure. At the end of the day, there was a lot of conversation about this, but the end of the day the recommendation that went forward is that lines eight inches, nominal line size eight inches and up are going to be brought into this governance with different requirements and a minimum standard of care which would be recommended by PHMSA at a future time.
I’m going to try to go look at the actual voting slide. Let me tee this up a little bit. It might be helpful. One of the things that happens in these committee meetings is PHMSA is putting up recommended language for the committee to consider, trying to hear what’s being talked about in the room, and captured that so that you can get to conclusion, and formalize a recommendation.
For pipe, nominal pipe size of eight inch and larger, the recommendation is design, installation, construction and initial construction requirements, damage prevention, public awareness, line markers, and leakage surveys, emergency response plans. There was some very interesting conversation around leakage survey, and how leakage surveys are done currently on gathering systems.
There was consensus in the room — both industry and public stakeholders — that the idea of leakage surveys makes sense. The challenge is the cost and practicality. The public stakeholders took a pretty firm position, I would say, that we need to make it clear that we’re going to be moving toward leakage surveys for these smaller lines. This is probably longer term that this will occur.
Kind of the bottom line here, and I would have taken a thousand dollar bet that there was no way this was going to happen before the meeting, but it did in fact happen. I would have lost the bet [laughs] if I would have taken it. The bottom line here is that nominal line size eight-inch pipeline operated about 125 PSI is going to be incorporated into this gathering rule as it gets formalized and rolled out.
There will be an adoption time. I’m sure there’ll be additional conversation about how some of these things are going to be implemented and the details of the implementation. I made the comment to some people on the side that this was a high theater for this kind of activity.
I’m going to read what was written on the final voting slide. This is basically the recommendation that came from the GPAC to PHMSA. I think it’s important to note that these things can be changed as they work their way through the process. This is not necessarily a final recommendation. But in my experience, they don’t change a lot. Here’s what the committee voted on, related to this part of the conversation.
“The proposed rule is published in the federal register, and the draft regulatory evaluation with regard to the scope of newly regulated gas gathering, and 192.8 (b) and (c) are technically feasible, reasonable, cost-effective, and practical if PHMSA considers the following.
“Establish an initial framework to build upon based on future information and experience. Set a minimum set of requirements for pipelines 8.625 inch or greater, considering, for example, design, installation, construction, initial inspection and testing, damage prevention for new and replaced pipelines, line markers, leak surveys, and repairs, public awareness, and emergency plans giving due consideration to the GPAC discussion on leak surveys.
“Consider applying a PIR concept for additional requirements to provide safety and environmental protection for larger pipelines, for example, greater than 12.75 inches. Ensure that composite pipe is adequately addressed to minimize the impact on its continued use.”
The thing that, to me, is most compelling is the fact that this is going all the way down to an 8-inch line size. There was a lot of conversation in the committee about unintended consequences. A couple of pieces of the language that I think are important to pay attention to.
One is, “Set a minimum set of requirements.” They didn’t say what the minimum set of requirements needs to be, but they’re basically asking that PHMSA set a floor and say that at a minimum, if you’re running an 8.65 inch or greater pipeline, you ought to be doing these things.
They also talked about some of those things might be sooner. Some of them might be later. In particular, they talked about giving fairly long runway to leak surveys in particular to allow for the vendor community to look at what might be possible given emerging technologies, satellite imagery, UAVs, and other things.
It was an interesting trip to Washington, D.C. this week, that’s for sure. Again, we will link up the presentations. There will be a transcript of the testimony. I think it’d be very interesting to people that are interested in the details of this to actually read the testimony. We’ll see if we can’t get that linked up.
It might not go up as the same time as the episode, but we keep these pages updated, so if this episode’s been out for a while, we’ll likely have gotten linked up to the transcripts, final presentations, and voting slides so that the information that’s on the public record can be available through the website.
Well, I hope you enjoyed this episode of the Pipeliners Podcast, and our conversation about the recent GPAC meeting and the Gas Gathering Rule. Just a reminder before you go, you should register to win our customized Pipeliners Podcast YETI tumbler. Simply visit pipelinepodcastnetwork.com/win to enter yourself in the drawing.
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Russel: If you have questions, ideas, or topics that you’d be interested in learning about, please let us know on the Contact Us page at pipelinepodcastnetwork.com, or reach out to me directly on LinkedIn. Thanks for listening. I’ll talk to you next week.
Transcription by CastingWords