Interpretation Response #PI-23-0020

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

Interpretation Response Details

Response Publish Date: 06/10/2024

Company Name: Hanna Oil and Gas Company

Individual Name: Mr. Sam Hanna

Location State: AR Country: US

View the Interpretation Document

Response text:

Mr. Sam Hanna
Pipeline Operations Manager
Hanna Oil and Gas Company
60 S 6th Street
Fort Smith, AR 72901

Dear Mr. Hanna:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated October 3, 2023, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to a change in classification of an 8-inch diameter natural gas pipeline in Arkansas from a transmission line to a gathering line.

You stated Hanna Oil and Gas Company's Arkoma Main Sales 8-inch diameter pipeline directly connects to Enable "Line O" Transmission pipeline 8.3 miles away from your central compressor station. You also stated that the Arkoma Main Sales 8-inch diameter pipeline was installed in October of 2001. In addition, you provided your pipeline layout on aerial photos and referred to the latest definitions from American Petroleum Institute (API) Recommended Practice (RP) 80 Second Edition (March 2020).¹ You stated this pipeline is currently classified as a Class 1 location transmission pipeline under Part 192 regulations. You asked, based on the November 15, 2021, Gas Gathering Pipelines final rule, whether this pipeline should be regulated as a Type C regulated gas gathering pipeline.

¹ 1st edition (April 2000) of API RP 80 is incorporated by reference in Part 192

To respond to your request, the current, relevant portions of §§ 192.8 and 192.9 are reprinted below:

§ 192.8 How are onshore gathering pipelines and regulated onshore gathering pipelines determined?

§ 192.8(a)(4) The endpoint of gathering, under section 2.2(a)(1)(D) of API RP 80, may not extend beyond the furthermost downstream compressor used to increase gathering line pressure for delivery to another pipeline.

§ 192.8(a)(5) For 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 (incorporated by reference, see § 192.7) and this section."

§ 192.8(c) For purposes of Part 191 of this chapter and § 192.9, the term "regulated onshore gathering pipeline" means:
(1) Each Type A, Type B, or Type C onshore gathering pipeline (or segment of onshore gathering pipeline) with feature described in the second column of table 1 to paragraph (c)(2) of this section that lies in an area described in the third column;

Type C onshore gathering pipeline:
Outside diameter greater than or equal to 8.625 inches and any of the following:
—Metallic and the MAOP produces a hoop stress of 20 percent or more of SMYS;
—If the stress level is unknown, segment is metallic and the MAOP is more than 125 psig (862 kPa); or
—Non-metallic and the MAOP is more than 125 psig (862 kPa)

§ 192.9 What requirements apply to gathering pipelines?
§ 192.9 (e) Type C lines. The requirements for Type C gathering lines are as follows:
(1) An operator of a Type C onshore gathering line with an outside diameter greater than or equal to 8.625 inches must comply with the following requirements:

(i) Except as provided in paragraph (h) of this section for pipe and components made with composite materials, the design, installation, construction, initial inspection, and initial testing of a new, replaced, relocated, or otherwise changed Type C gathering line, must be done in accordance with the requirements in subparts B through G and J of this part applicable to transmission lines.

The Arkoma Sales 8-inch diameter, 8.3 miles long pipeline is not subject to the limitation of incidental gathering in 192.8(a)(5). The pipeline meets the end point and mileage requirements of §§ 192.8(a)(4) and 192.8(a)(5). The pipeline is in Class 1 location. Assuming that the central compressor station is the furthermost downstream endpoint of gathering as defined in§ 192.8(c) and API RP 80, 1st Edition, the Arkoma Main Sales 8-inch diameter, and 8.3 miles long pipeline may meet the definition of an incidental gathering pipeline as a Type C regulated onshore gathering pipeline and then must comply with the requirements at § 192.9(e) for Type C lines.

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