Interpretation Response #PI-23-0003
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Riverfront Exploration, LLC
Individual Name: Ms. Jennifer Sebo
Location State: AR Country: US
View the Interpretation Document
Response text:
Ms. Jennifer Sebo
Production Tech
Riverfront Exploration, LLC
109 North 6th Street
Fort Smith, AR 72901
Dear Ms. Sebo:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated November 7, 2022, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192.8 for the Riverfront Exploration, LLC (Riverfront) Washburn Creek 6-inch diameter and Fort Chaffee 2-inch diameter natural gas pipelines (Riverfront pipelines) in the state of Arkansas.
You stated the Fort Chaffee 2-inch diameter pipeline has a maximum allowable operating pressure (MAOP) of 1,200 pounds per square inch gauge (psig) and operates at 17.57 percent specified minimum yield strength (SMYS). You stated the pipeline is in a Class 1 location and is not in a high consequence area (HCA). You stated the pipeline is 216 feet long from the compressor station to its connection to Blackbear transmission line. You stated the Washburn Creek 6-inch diameter pipeline has an MAOP of 1,000 psig and operates above 20 percent SMYS. You stated the pipeline is in Class 1 location and is not in a HCA. You stated the pipeline is 0.877 miles long from the compressor station to its connection to the Enable Transmission Line. Based on the information you provided, both Riverfront pipelines upstream of the compressor stations are connected to wells as gathering lines. You stated that both Riverfront pipelines are currently regulated as transmission pipelines. However, you ask PHMSA whether the pipelines qualify as Type R gathering pipelines.
In an e-mail dated February 6, 2023, PHMSA asked Riverfront Exploration, "[s]ince the transmission line definition did not change what makes the pipeline gathering of any type? What made the pipeline to be designated as transmission in the first place?"
On the same day you responded to PHMSA stating that both the Fort Chaffee and the Washburn pipelines were designated as transmission lines by previous operators before Riverfront acquired them and, therefore, you could not speak on their behalf of why they determined these pipelines as transmission pipelines.
Table 1 to Paragraph(c)(2) of § 192.8 in the November 15, 2021[86 FR 63296], Safety of Gas Gathering Pipelines final rule describes Type R pipelines as onshore pipelines in Class 1 and Class 2 locations that do not meet the Type A, Type B or Type C criteria.
Per § 192.8(a)(5), new, replaced, relocated or otherwise changed gas gathering pipelines installed after May 16, 2022, the endpoint of gathering under sections 2.2(a)(1)(E) and 2.2.1.2.6 of API RP 80 (incorporated by reference, see § 192.7)—also known as "incidental gathering"—may not be used if the pipeline terminates 10 or more miles downstream from the furthermost downstream endpoint as defined in paragraphs 2.2(a)(1)(A) through (a)(1)(D) of API RP 80.
Pursuant to § 192.8(c)(3), a Type R gathering line is subject to reporting requirements under 49 CFR Part 191 and is not considered a regulated onshore gathering line under 49 CFR Part 192.
Based on the information you provided, the Riverfront pipelines are less than 8.625-inches in diameter, operate in Class 1 locations, and are less than 10 miles long from the furthermost downstream endpoint to the gas transmission pipelines. Therefore, PHMSA agrees with your assessment that the two Riverfront pipelines meet the definition of a Type R gathering pipeline and are subject to the 49 CFR Part 191 reporting requirements.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
John A. Gale
Director, Office of Standards
and Rulemaking