Underground Construction - February 2022 - 13

quired to comply with existing requirements for Type B gas gathering
lines, and requirements to develop and implement emergency plans.
Type B gathering lines are lower-stress pipelines in Class 3, Class
4 and certain Class 2 locations, which must abide by corrosion control,
MAOP establishment, leak surveys and repair requirements,
all similar to requirements for transmission pipelines.
Type C gathering lines with smaller diameters (above 8.265
inches) that could not directly aff ect homes and other structures
have fewer requirements that are limited to damage prevention,
emergency plans and public awareness. Th ese requirements address
known causes of pipeline failures including excavation damage, corrosion,
and inadequate design and construction standards.
Th e fi nal rule also requires Type C operators to submit safety-related
condition reports starting on May 16, 2022, and further
provides that operators of existing, but previously unregulated,
pipelines must determine whether these lines are Type R or Type C
by Nov. 16, 2022. Finally, the rule requires operators to treat new,
replaced, relocated or otherwise changed incidental gathering lines
that extend 10 or more miles in length as regulated transmission
lines, eff ective as of May 16, 2022.
PHMSA's rationale for these new requirements is twofold. Th e
agency argues that gathering lines, particularly in more recent
shale areas, have dramatically grown in size to 24, 30 and 36 inches
and are operating at high pressures, as much as 1480 psig in
Pennsylvania, for example. Second, the agency wants to work hand
in glove with other Biden administration agencies to reduce methane
emissions from pipelines.
Bore_Spacer-Ad_UC_2020.pdf 1 2/24/2020 10:40:27 AM
Th e GPA/API petition for a delay in implementation deadlines
states the incident and safety related condition reporting requirements
that go into eff ect on May 16, 2022, create signifi cant compliance
obligations. Its separate request that PHMSA reconsider the
rule rests on its belief that gathering lines at 12.75 inches or less in
diameter do not present a signifi cant risk to public safety. Th e two
groups also state the agency " ignored substantial cost information
in concluding that the benefi ts of applying certain requirements to
these pipelines justifi ed the costs. " Th e 2021 fi nal rule estimates
annual costs at $13.7 million per year.
George Wilkinson, Jr., an attorney with Vinson & Elkins in
Houston, said, " We anticipate that the costs will be higher. "
In their petition for a " stay, " the GPA and API argued: " ...the
unnecessarily short compliance deadlines that the Agency chose
to adopt in the Final Rule (in the midst of historic infl ation and a
global supply chain crisis resulting from the COVID-19 pandemic)
will escalate the costs involved dramatically. "
Th ey are particularly concerned with the requirement that operators
of existing but previously unregulated incidental gas gathering
lines that extend 10 or more miles in length will need to convert
those pipelines to transmission service if any portion is repaired,
replaced or otherwise changed, on or after May 16, 2022.
Th e two associations are arguing a reasonable compliance deadline
for pipelines greater than 12.75 inches in outside diameter is
May 16, 2023, and a reasonable compliance deadline for pipelines
12.75 inches or less in outside diameter is May 16, 2026. *
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Underground Construction - February 2022

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