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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-23-0011

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Paradox Pipeline

Individual Name: Mr. Todd Westcott

Location State: UT Country: US

View the Interpretation Document

Response text:

Mr. Todd Westcott
Paradox Pipeline
PO Box 1199
Monticello, UT 84535

Dear Mr. Westcott:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to the requirements in 49 CFR § 192.9.

You asked for PHMSA's clarification regarding requirements for Types B, C, and R gathering pipelines. You asked whether these types of gathering lines are exempt from the self-implementing inspection and maintenance plan requirements in Section 114 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020 (PIPES Act of 2020, Pub. L. 116-260).

Section 114 of the PIPES Act of 2020 amended the pipeline safety statues at 49 United States Code (U.S.C) 60108. Section 60108(a)(1) requires each person owning or operating a gas pipeline facility or hazardous liquid pipeline to carry out a written inspection and maintenance plan. Section 114 of the PIPES Act of 2020 contains self-executing provisions that require pipeline operators to update these inspection and maintenance plans to address eliminating hazardous leaks and minimizing releases of natural gas. Section 114 also added a requirement that the inspection and maintenance plans address replacement or remediation of pipelines known to leak due to their material, design, or past operating and maintenance history.

Owners and operators of regulated gathering lines are subject to the requirements in 49 U.S.C. 60108.1 PHMSA defines Types A, B and C gathering lines as regulated onshore gathering lines in 49 CFR § 192.8(c). Section 192.8(c)(3) specifies that Type R gathering lines are not considered regulated onshore gathering lines under Part 192.

1 See 49 U.S.C. 60101(a)(3) and 60101(a)(21).

The self-implementing requirements in Section 114 of the PIPES Act of 2020, therefore, apply to operators of Types A, B and C gas gathering lines. Such operators are required to have inspection and maintenance plans in accordance with 49 U.S.C. 60108 and update those plans in accordance with the requirements in Section 114 of the PIPES Act of 2020. Type R gas gathering lines are not considered regulated onshore gathering lines and, therefore, are not subject to the requirements in Section 114 of the PIPES Act of 2020.

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

Regulation Sections

Section Subject
192.9 What requirements apply to gathering lines?