As an ever-increasing amount of gas is extracted and carried through pipelines, along come more reports of serious pipeline incidents. A new gas-gathering rule that has been issued by the US Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) will soon expand oversight to all onshore gas-gathering pipelines. The goal: To make all processes associated with pipelines safer. The new rule includes about 425,000 miles of lines that had not previously been documented in annual reporting.
The newly targeted pipelines were traditionally low-pressure lines in rural areas, but with modern frackuring and different drilling methods that have increased pressures in gathering lines—similar to that of transmission lines—the new rule is crucial to ensuring the safety of the public and the environment. Though annual reporting will not be required until March 2023, the effective date of the final rule was 16 May 2022. This means all pipeline incidents and events that occur after this date must be reported, as well as all the assets that are in place.
As annual reporting for the new PHMSA rule looms, how can pipeline operators be ready for the changes?
Noteworthy Benchmarks for the New Rule
The new rule, simply put, is an attempt to protect people, property, and the environment—matters most of us can agree are exceptionally important. The regulation will be crucial to safety as the demand for domestic oil production increases, andundoubtedly, some operators will face hurdles in the process.
Several notable benchmarks organizations will have to meet to remain in compliance include
- Annual reporting on pipeline mileage, facilities, commodities transported, miles by material, and installation dates.
- Leak surveys.
- Line markers.
- Creating a public awareness program.
- Reporting incidents and other safety concerns.
- Corrosion control.
- Identifying assets.
- Preparing an emergency response manual.
Items That Will Require Ongoing Attention
All the pieces of the new rule will require more timeand more 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 people within the community regarding gas lines. Operators will need to coordinate with agencies such as fire departments, police departments, and local damage-prevention groups to help maintain safety and integrity of the pipelines.
Operators should also consider meeting with community members and first responders to make sure everyone is on the same page and aware of the pipelines in their community, as well as how they will respond with coordination and collaboration should a hazardous incident occur.
Being Prepared Before Reporting Is Required
One piece of good news for operators is that, since 2006, a good deal 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 who prepare now to report later will realize they likely have a lot of the processes already in place to achieve compliance with the regulation.
Here are three ways operators can remain ahead of the curve.
- Identify pipeline beginning and endpoints, along with other important data.
This might be the most important step, as endpoints must be designated by 16 November 2022. Operators will have to identify materials and miles of pipe, as well as have it mapped out. Start by looking at all the assets already documented for annual reporting, and if everything is not accounted for, identify where there’s a gap. This may require bringing in a team of researchers or engineers to pull together all the paperwork to determine what kind of pipelines you have, what the diameter is, and what the materials are. It’s important to clarify that there is no room for guesswork when it comes to this part of the process. Organizations will need to document the methodology to demonstrate transparency and operational safety in all areas. Having this data will also be important in creating an emergency plan. - Develop a public awareness plan.
First, operators should use markers to label areas where there are pipes. This will ensure residents in the community are aware of any lines running through any specific area. After marking them, reach out to residents within the community to be sure they are aware of the locations where pipes live, as well as the hazard of those gathering lines. Also, make them aware of any information regarding an emergency response plan. - Review workplace policies and procedures.
Looking over policies and procedures now will ensure compliance with the new requirements, and it also presents an opportunity to learn about an organization’s agility when it comes to making changes. When annual reporting becomes mandatory, operators will have to adapt processes and procedures to meet the new regulations.
Moving Forward
Operators should know that considering the future implications of the new PHMSA rule is extremely important. Integrating the new rule is relatively straightforward but combining that with other PHMSA initiatives could be complicated, especially considering some of the directives under the PIPES Act of 2020. However, by doing the homework now and thinking through the details carefully, operators are setting themselves up to successfully report on key benchmarks in the near future, bolstering worker and public safety while ensuring business continuity.
