July 2022, Vol. 249, No. 7
Features
How Operators Can Respond to PHMSA Gas Gathering Reporting Rule
By Tom Meek, Vice President of Regulatory Compliance, Veriforce
In the last 15 years, the amount of gas that has been extracted and transported through pipelines has increased immensely, along with more reports of serious pipeline incidents.
A new gas gathering rule, issued by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), expands safety oversight to all onshore gas-gathering pipelines, with the intent to make all processes associated with pipelines safer.
That includes about 425,000 miles (684,000 km) of onshore gas-gathering lines not previously documented in an annual report.
Newly targeted pipelines were traditionally low-pressure lines in rural areas, but with modern fracking and different drilling methods that increase pressures in gathering lines – similar to that of transmission lines – the new rule is instrumental in ensuring the safety of both the public and the environment.
While annual reporting as it relates to the mandate won’t be required until March 2023, the effective date of the final rule is May 16, 2022. All pipeline incidents and events that occur after this date must be reported, as well as all the assets in place.
Notable Changes
The new rule, quite simply, is an attempt to protect people, property and the environment – matters most all of us can agree are extremely important. The regulation will be critical for safety as the demand for domestic oil production increases, but there’s no doubt some operators will face hurdles in the process.
Several benchmarks that organizations will need to meet to remain compliant include:
- Annual report, including pipeline mileage, facilities, commodities transported, miles by material and installation dates
- Corrosion control
- Assets identification
- Leak surveys
- Line markers
- Emergency response manual preparation
- Public awareness program creation
- Incidents and other safety concerns reporting
Ongoing Attention
All of these items will require more time manage, and time is money. To execute public awareness, an ongoing practice, it will be mission-critical for pipeline operators to remain in close contact with emergency responders and community members near gas lines.
Operators will need to coordinate with agencies, such as fire departments, police departments, and local damage prevention groups, to help maintain integrity and safety of the pipelines.
Operators should meet with the community and first responders to ensure everyone is aware of the pipelines in their community, as well as how they will work together, should there ever be a hazardous incident.
Prepare to Report
The good news is that since 2006, much of the pipeline infrastructure has been put into place with new gathering systems, so many companies will already have the information documented. Still, it’s always best to be ready for any major changes that are coming down the pipe.
Operators will do themselves a favor by preparing now to report later. Here are four tasks operators can tackle now as annual reporting becomes a requirement.
- Identify pipeline start and endpoints, along with other data.
Operators will have to identify materials and miles of pipe, as well as have this mapped out. They should review all assets documented for annual reporting so they can assess gaps if items are missing. That might require bringing in a team of researchers or engineers to determine what kind of pipelines they have, what the diameter is, and what the materials are. Organizations will need to document the methodology to demonstrate transparency and operational safety in all areas.
- Use markers to label areas with pipes.
Use markers to label areas with pipes to ensure residents in the community are aware there is a pipeline present.
- Develop a public awareness plan.
After marking pipes, reach out to residents within the community to be sure they are aware of the locations where pipes exist, as well as the hazard of the gathering lines. Also, make them aware of any information that will help facilitate a swift, safe response if there is an emergency.
- Review workplace processes and procedures.
Looking over processes and procedures will ensure compliance with the new requirements. Doing so presents an opportunity to learn about an organization’s agility when it comes to making changes. With the new rules in effect, operators will have to adapt processes and procedures to meet the changing regulations.
Operators should consider future implications associated with noncompliance. Integrating the new rule is relatively basic but combining that with other PHMSA initiatives could be complicated, especially when it comes to some of the directives under the PIPES (Protecting Our Infrastructure of Pipelines and Enhancing Safety) Act of 2020.
By doing their homework now and thinking through the details carefully, operators are setting themselves up to avoid safety and reporting issues in the future, both of which could have significant impacts on worker well-being and business continuity.
Author: Tom Meek joined Veriforce in 2016, bringing more than 20 years of pipeline operations, safety, training and regulatory compliance experience to the role of vice president of Regulatory Compliance. Prior to working for Veriforce, Tom was responsible for the leadership of pipeline operations crews for Kinder Morgan, including three compressor stations, two regional office facilities and multiple natural gas transmission pipelines.
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