Cost Effective Way to Determine Your Gas Gathering Lines DOT Jurisdictional Status

New gathering rule definition/regulatory background
(Title 49, CFR Part 192.8)

On March 15, 2006, PHMSA published its final rule on the definition of gas gathering lines. (The definition of gathering lines has been at issue since 1974.) This rule depends largely on API RP 80 to define the lines that are “gas gathering”. Of these lines “regulated onshore gathering lines” will be classified either Type A or Type B. The line type is determined by population density around each pipeline and its operating pressure/stress level.

The old definition regarding gathering lines transversing through a residential, commercial and/or city limits will no longer be used to identify jurisdictional gathering.

The final rule took effect April 14, 2006. Compliance dates for both Type A and B lines vary by task and range from October 15, 2007 to April 15, 2007.

What does this mean? Operators of gas gathering pipelines should perform the following activities in response to this rule.

1. Identify gathering lines meeting the current definition of “gas gathering by conducting a class location study to determine which lines, if any, would be Type A or B regulated onshore gathering.
2. Determine the operating stress level of metallic gas gathering lines and the maximum operating pressure non-metallic lines.
3. Develop and implement compliance programs for all jurisdictional gathering lines by the applicable deadlines.

Cost effective solution

The tendency for Producers and Gathering Operators is to say “our pipelines are not under DOT jurisdiction” and dismiss the issue. This is because their pipelines are a means to get their product to sales, they are not in the pipeline business. I have worked with Operators that stated their gathering lines were non-jurisdictional until they experienced a leak or incident. Then that “sleeping dog” comes to life and becomes a breathing monster.

The cost to assess your gathering system is extremely low compared to that possible “sleeping dog”. The most cost effective way to conduct a class location survey is to plot your pipeline system on a current aerial base. This can be done with existing GPS coordinators and imported into a mapping system, (i.e.. ArcView), if you do not have GPS coordinates, I recommend having your system GPS utilizing sub-meter accuracy GPS equipment with exportable data capabilities (i.e. Trimble).

Field reconnaissance vs administrative review

Once you have your gathering system plotted on a current aerial you can conduct an administrative review with field personnel identifying structures within the 220-yard class location criteria. I also recommend shading the 220-yard criteria and adding pipeline footages. This is easily accomplished with most mapping software packages. If your administrative review clearly documents your gathering system is in a rural area (Class I location), then you have completed your pipeline assessment and you are able to demonstrate your gathering facilities are non-jurisdictional to DOT.

In the event your administrative review indicates cluster of structures within the 220-yard criteria, then I recommend a field reconnaissance to document all living units, commercial building and community centers.

This can be done very economically, usually in a day or two, using an offset laser that connects to your GPS equipment. This tool allows you to shoot and plot all living units and/or commercial buildings from the road and not trespass onto people’s property. This also will help you from having to drive down the right-of-way. Population clusters usually are at road intersections.

After completing your house count/class location survey, export your GPS data into your mapping software to create your house count layer. This will give you the opportunity to evaluate your system and determine which sections of your gathering system may be in a Class 2 or 3 locations and possibly be under DOT jurisdiction.

This process will minimize any “sleeping dogs” that may exist in your gathering system and will allow you the insight to take action, if any action is necessary, to reduce your pipeline safety risk to the public.

In addition to minimizing your pipeline safety risk, the benefits of this project are 1) have an accurate pipeline system map 2) have a class location survey well documented and 3) since the system was GPS and is electronically available it can easily be transmitted to the, Office of Pipeline Safety, Homeland Security and other State Agencies.

For additional information regarding reducing your pipeline safety risk visit www.pipelineaccidentprevention.com