Maybe you saw it coming; maybe it crept up on you. But ready or not, it’s time to act on the new definition and safety requirements for onshore gas gathering lines.

With a well-planned survival strategy, your company can stay on the right side of the rule.

The definition of a gathering line – what it is, what it’s not, and what safety standards it has to meet – has been discussed and debated throughout the industry for many years. It’s hard to imagine that many operators were taken by surprise when the so-called “gathering rule” became effective in April 2006, a month after it was added to the books by the Pipeline and Hazardous Materials Safety Administration (PHMSA), United States Department of Transportation (DOT).

What is surprising – and a bit alarming – is how few companies have begun the process of compliance. With a series of milestones marking phases of the process, compliance must be complete by 2009. In the corporate world, two years isn’t much time.

In a nutshell, 49 CFR Part 192 adopts the American Petroleum Institute’s definition, API RP 80, to distinguish onshore gathering lines from other pipelines and production operations. It also establishes safety requirements for onshore gathering lines in rural areas, while revising the requirements for gathering lines in more densely populated areas. And it spells out a risk-based approach to determine which lines are subject to gas pipeline safety rules. The good news is that, finally, after years of quibbling over definitions, the haze has cleared. Now our industry can apply a uniform standard to planning, reporting and operating this type of asset.

The bad news is that, for some gathering operators, the rule could mean big changes – and big challenges. If any of your company’s pipelines are reclassified as regulated gathering lines – those near areas defined as non-rural – the time and money you’ll spend to comply could be significant.

Worse, not only could some of your pipelines come under heavier regulatory scrutiny, but some segments may even be reclassified from a gathering line to a transmission line. Considering the rigorous safety rules applied to transmission lines, that change could punch a big hole in your profitability. You would seriously have to consider whether the additional regulatory compliance costs and exposure fits your business plan.

Fail to comply at your own peril. The enforceability of the new provisions of 49 CFR Part 192 has yet to be tested. But, in the past, the PHMSA’s Office of Pipeline Safety has proven quite willing to use audits and enforcement actions, both to encourage compliance and to admonish those who violate existing rules. Even the simplest of violations may carry a hefty penalty.
The most important step you can take to protect your company is to evaluate all of your pipelines and make sure every foot of them complies with the new safety regulations.

So, why haven’t more companies done that? It may be that they are so intimidated by the process that they don’t know where to start. And for good reason. The system-wide mapping, review and documentation, along with any necessary remediation, may be easy for some companies that have ample resources and experience in dealing with new DOT regulations. Others may be well-advised to seek the assistance of a third party for all or part of the project.
For example, you could consult with a service company just to be sure you understand the regulations and processes. Or, you could commission the company to determine which of your pipelines fall into the new rule. Using Geographic Information Systems (GIS), the service company can combine relational databases with spatial interpretation to pinpoint the routes of your pipelines and identify the structures in their paths. You’ll need to know that information to determine the risk-based requirements for pipe wall thickness and maximum allowable operating pressures, for starters.

Smaller pipeline operators may find it more practical to turn the entire project over to a third party. A full-service company can handle it all, from identifying the affected pipelines to determining what it will take to bring them into compliance. It can even conduct cathodic protection surveys, make the necessary upgrades, patrol the pipes to scout for leaks and keep the maintenance records now required for reporting.

How can you know whether your company needs help to comply with the new rule for onshore gas gathering lines? Here’s a checklist of questions you should ask to determine whether you can adequately address the issue on your own.

If you have the answer to only one of the above questions, it should be the last one, number 7. And the only right answer is “yes.” With a partner who has been through audits themselves or helped other clients through the process, you will feel more confident that you are meeting the burden of proof necessary to survive the new gathering rule.