“Once upon a time,” gathering systems were the stepchildren of the natural gas transportation industry: Nobody paid any attention to them. (Even though we’re beginning this article with four memorable words, this is not a fairy tale.) In this new century, much greater attention is being paid to the safety of systems that, until now, weren’t much thought about.

Once upon a time, companies could lay pipe and – virtually – forget about it. Gathering lines that were laid in the 1940s and 1950s were never tested; their condition and location were ignored. Once in the ground, pipe was too easily forgotten. The habits formed in the middle of the last century didn’t get unlearned, either: production companies continued to establish gathering systems without giving much thought to potential risks and liabilities, especially since – even in the late 1980s – those gathering systems could be in the middle of nowhere.

You may remember some of the comments people in the industry used to make about gathering systems: “This isn’t real dangerous – it’s clean gas, it’s low pressure.” Or “The chance for explosions is also low.”

“Once upon a time” is long gone. It’s a new century, after all.

PHMSA and the 2006 Rule
It has been two years since the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) published its final rule on the definition of gas gathering lines: March of 2006. This rule completely changed the previous regulations for gas gathering.

Pipelines that were previously considered to be regulated gas gathering may now be exempt. Likewise, other pipelines that were previously considered to be exempt gas gathering are now going to be regulated.

Once Unregulated, Now Under the ’Scope
Anyone could build a gathering system and attach it to a main pipeline without thinking about regulations: Today, regulations encompass both gas and liquids gathering systems. Operators of gathering systems, who built them simply as go-to-market lines, may say, “Oh, those regulations don’t apply to us.” But they do apply. Their enforcement is being tightened not only nationally (via 49 CFR 192) but locally as well – right down to the City Council level.

Gathering system operators may not recognize the substantial increase in the risks they face.

First of all, urban growth has changed the landscape – literally. Gathering systems that used to be remote are now increasingly surrounded by development. People move to an area because of its “rural feel” without realizing that a gathering system may have been put in place and buried years beforehand. Increasingly, lines run under city streets and other developed property. The result is an increase in the number of high-consequence area (HCAs) that gathering system operators didn’t used to have to consider.

Second, as a right-of-way specialist said several years ago, a number of companies simply don’t have the infrastructure to implement remedial and pipeline integrity management (PIM) programs that are mandated by regulating authorities.
When the industry was smaller, most employees learned from the bottom up; training varied vastly but managers and maintenance crews did get trained. Today, on-the-job training may not be able to cope with the immense range of regulatory demands, especially when it comes to the former stepchildren represented by gathering systems.

In many cases, pipeline maintenance programs:

Today, the industry is structurally different in many ways and companies have often moved into the hands of investors who may not completely understand their responsibilities under government regulations. PIM and PIM plans are mandated.

To gathering system operators – to you – we would reiterate some of the points we have made in previous “Forward Thinking” articles: To reduce risks, you have to go out and evaluate the condition of pipelines, or have them inspected by professional third-party crews – then repaired if necessary and the repairs fully documented.

A Couple of Consequential Examples
Corrosion can dramatically reduce equipment reliability and cause premature failure of a gathering line. Does this happen? You bet. Remember that a natural gas transmission pipeline ruptured near Carlsbad, New Mexico a few years ago, causing a dozen fatalities and almost $1 million in damage. The cause was traced to corrosion damage.

You prevent this kind of risk by protecting your gathering system cathodically; and maintaining this protection is critical to meeting some of your regulatory – and operating – requirements.

Even as a gathering system operator, you have to identify High Consequence Areas. You must locate your lines precisely to determine which ones are affected by which regulatory authority (e.g., the Pipeline Act of 2006? Other Federal regulations? State authorities? Local governments?) You have to be able to prove to regulators that you have an IMP for these assets, and that you are following this program absolutely, with digs, integrity tests and more effective record-keeping. All these make your system (and the industry) much, much safer.

So whether you are operating 450 wells or 4,500 of them, whether you’re operating in a single state or eight or nine, running your gathering system without a strong safety infrastructure is like juggling live hand grenades: No matter how good you think you are, you could be found negligent in the event of an “incident.”

No More Invisible Pipelines
When it comes to the regulators, gathering systems no longer fall into the category, “out of sight, out of mind,” as they did several years ago. Many gathering system operators realize that they have to institute a formal set of procedures, based on recognized steps.

Whether you’re operations or management, consider the following crucial components of a modern safety program – and then asking EMS about the ones you’re missing. (Consider this a checklist.)

These components are not unique, unless you do not have them for your gathering system. These have already been “institutionalized” by major interstate pipeline operators over the past decade. They will work for you.

Despite accidents and fatalities, transportation of hydrocarbons via a pipeline is still the safest modality; safe because of increased regulation across the national infrastructure and operators’ greater attention to programmed safety. Once upon a time, gathering systems got a pass. Now, they won’t.

Are you ready for the 21st Century?