American Oil and Gas Reporter - May 2016 - 31

tive railroad.
RP-80 does not impose any property,
mileage, or crossing restrictions on using
the incidental gathering line designation
under the current federal rules.
If adopted as proposed, these changes
could narrow substantially the scope of unregulated production operations, and
would bring the range of potentially-regulated gathering operations to points
much closer to the wellhead. Use of the incidental gathering line designation also
could be restricted significantly, requiring
operators to reclassify many of these
lines as fully-regulated transmission lines.
New Safety Standards
PHMSA also is proposing to apply the
federal pipeline safety standards to certain
gas gathering lines in Class 1 locations.
Specifically, the NOPR would partially repeal the exemption and apply a limited set
of Part 192 safety standards to Class 1 gas
gathering lines that have a maximum allowable operating pressure (MAOP) that

produces a hoop stress of 20 percent or
more of specified minimum yield strength
for metallic lines, or more than 125 psig
for nonmetallic lines that are at least
eight inches in outside diameter.
Operators of these "Type A, Area 2"
gathering lines would have to comply with
the same safety standards that apply to lower-stress, "Type B" gathering lines. That
includes implementing damage prevention
and public awareness programs, establishing MAOP, installing line markers, conducting leak surveys for all lines, and providing corrosion control for metallic lines.
The requirements for design, installation,
construction, initial inspection, and initial
testing would apply to any new, replaced,
relocated, or otherwise changed lines.
To address a U.S. Government Accountability Office recommendation, operators of Type A, Area 2 gathering lines
also would be required to comply with Part
192's emergency response requirements.
Finally, PHMSA is proposing to apply
the federal reporting requirements to all gas

gathering lines, including Class 1 gas
gathering lines that do not meet the stresslevel and outside-diameter criteria to qualify as regulated, Type A, Area 2 lines. To
comply with a statutory limitation in the
federal Pipeline Safety Act, gathering
line operators would not be required to submit any information to the National
Pipeline Mapping System. PHMSA intends to use the information collected in
these reports to determine whether additional gathering line regulations are necessary.
The deadline for submitting comments
on the NOPR is June 7, although several
pipeline industry trade organizations filed
a request to extend that deadline. After the
comment period closes, PHMSA must
consider the information provided and
present the NOPR to a federal pipeline
safety advisory committee for consideration. The final step in the rule-making
process would be issuance of a final rule
containing new federal safety standards
that have the force and effect of law. ❒

Agency Approves Pennsylvania Rules
WEXFORD, PA.-Following on the
heels of two court decisions that refused
to enjoin its action, the Pennsylvania Independent Regulatory Review Commission (IRRC) on April 21 voted 3-2 along
party lines to approve a comprehensive
rewrite of regulations governing oil and gas
surface operations in the state.
The Pennsylvania Independent Oil &
Gas Association notes that the vote on the
Chapter 78/78a, Subchapter C final form
rule making came after seven hours of tes-

timony, including numerous industry supporters who argued that the Department of
Environmental Protection failed to follow
a legislative directive to promulgate separate rules for the state's conventional and
unconventional industries, that DEP greatly underestimated the cost of the rules, and
that the agency had not demonstrated the
need for tough new regulations for conventional oil and gas wells.
PIOGA and the Pennsylvania Independent Petroleum Producers Association

(PIPP) attempted to obtain a court order
enjoining IRRC from considering the
proposed rules. On March 24, PIPP filed
a challenge in Pennsylvania Commonwealth Court to the manner in which
DEP and the state's Environmental Quality Board formulated and approved the regulation package, and PIOGA was granted
leave to intervene on April 5.
However, the Commonwealth Court deSEE AGENCY PAGE 105

June 29-30 | Houston | Texas

Speakers Include: Liberty Resources, Zarvona Energy, Chevron, Murphy Oil, EP Energy,
Freeport McMoran, Endurance Resources, BlueStone Natural Resources, Plus
Danny Durham
Director Of Global
Upstream Chemicals
Apache Corporation

Anton Babaniyazov
Production Engineer
ConocoPhillips

Amjad Abdelrahman
Production Engineer
Anadarko Petroleum
Corpoation

Hank Owen
SR Operations
Manager
Concho Resources

www.production-chemicals-optimization.com
+1 800 721 3915 info@american-business-conferences.com
MAY 2016 31
American Oil and Gas Reporter - May 2016

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