# Onshore Gas Gathering FAQs for Type C and R Pipelines

- **operation:** document
- **citation:** PHMSA Guidance, Onshore Gas Gathering FAQs for Type C and R Pipelines
- **title:** Onshore Gas Gathering FAQs for Type C and R Pipelines
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2025-01-13
- **effective on:** 2025-01-13
- **summary:** Onshore Gas Gathering FAQs for Type C and R Pipelines Document Gathering-Type-C-and-R-FAQs-with-batch2.pdf (267.12 KB) The Onshore Gas Gathering FAQs for Type C and Type R Pipelines include general guidance on gas gathering and specific guidance on requirements applicable to Type C and Type R gathering lines. Issued Date: Monday, January 13, 2025
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Onshore Gas Gathering FAQs for Type C and R Pipelines

Document

 Gathering-Type-C-and-R-FAQs-with-batch2.pdf (267.12 KB)

        The Onshore Gas Gathering FAQs for Type C and Type R Pipelines include general guidance on gas gathering and specific guidance on requirements applicable to Type C and Type R gathering lines.

          Issued Date: Monday, January 13, 2025

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Title: Frequently Asked Questions (FAQs) for Types C and R Gas Gathering
Pipelines from the Final Rule titled “Safety of Gas Gathering Pipelines: Extension
of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other
Related Amendments,” Published November 15, 2021
Date: April 18, 2023, updated January 13, 2025
Summary:
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is issuing supplementary regulatory
guidance in the form of frequently asked questions (FAQs) on Types C and R onshore gas gathering pipelines
(gathering lines). FAQs for Types A and B gathering lines can be found on the PHMSA website. PHMSA
provides FAQs to help the public understand how to comply with regulations. Like all PHMSA guidance, FAQs
are not substantive rules, do not have the force or effect of law, and do not create new legal obligations. An
operator who demonstrates compliance with the FAQs, however, is likely to be able to demonstrate compliance
with the relevant regulations. If a pipeline operator chooses not to comply with the FAQs, the operator must be
able to demonstrate that the operator’s conduct complies with the regulations.
Table of Contents
General ..................................................................................................................................................................... 3
1. What is a gathering line? .................................................................................................................................. 3
2. Who regulates gathering lines? ......................................................................................................................... 3
3. Are all gas gathering lines regulated by PHMSA? ........................................................................................... 3
4. What is a regulated onshore gathering line within the inlets of the Gulf of Mexico? ...................................... 4
5. How do you calculate PIR if you are not obligated to establish an MAOP pursuant to § 192.9(e)(ii)? ........... 4
6. What constitutes a “building intended for human occupancy or other impacted site” in § 192.9(f)? .............. 4
7. When using method 2 in § 192.9(f)(1)(ii), can an operator of a Type C gas gathering line “cluster” buildings
intended for human occupancy as allowed in § 192.5? .................................................................................... 5
8. Am I required to maintain records for my Type B and Type C gathering lines? ............................................. 5
Reporting Requirements ........................................................................................................................................ 6
9. What are my reporting requirements for Type R lines? .................................................................................... 6
10. Are gathering lines operating at less than 0 psig considered Type R? .............................................................. 6
11. Am I required to obtain an operator identification number (OPID) for reporting-regulated gas gathering
lines (i.e., Type R)? ........................................................................................................................................... 6
12. Are Type R gas gathering lines required to notify PHMSA of flow reversals lasting more than 30 days
under § 191.22(c)(1)(v)? ................................................................................................................................... 6
13. Can I file my type R annual report along with my other gathering lines? ........................................................ 7
14. Are individual service lines (i.e., farm taps) directly connected to Type R gathering or production pipelines
required to be reported on a distribution annual report? ................................................................................... 7
Construction requirements .................................................................................................................................... 7
15. Must all existing pipelines that have been newly identified as Type C gathering lines pursuant to the final
rule issued in November 2021 be retrofitted to meet its design and construction requirements? ..................... 7
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16. When has a pipeline been “otherwise changed” for the purpose of the applicability of certain design,
construction, initial inspection, and testing requirements that PHMSA has adopted since initial construction
of the pipeline?.................................................................................................................................................. 7
17. Is overpressure protection required on my Type C gathering line? .................................................................. 8
18. Are Type C plastic pipe gathering lines subject to the design, installation, construction, and initial
inspection requirements in subparts B though G and J of part 192 applicable to transmission lines? ............. 8
19. For pipe made with composite materials, is notification under §§ 192.9(h) and 192.18 required for
replacement, relocation, or changes of 40 feet or less of composite pipe? ....................................................... 8
20. What are the requirements for composite Type C pipelines installed prior to the effective date of the rule? .. 9
Design Requirements .............................................................................................................................................. 9
21. Does an operator need to establish an MAOP for determining Type C gathering lines? ................................. 9
22. Can existing records be used to establish the MAOP of Type C gathering lines with an outside diameter
greater than 12.75 inches instead of using the highest actual operating pressure to which the segment was
subjected during the five years (60 months) preceding May 16, 2023, or five years (60 months) before first
becoming subject to the rule, whichever is later? ........................................................................................... 10
23. What is the length of time required to hold a “highest actual operating pressure” to claim that pressure as
the MAOP for a gathering line under § 192.619(a)(3) or (c)? ........................................................................ 10
24. How do I calculate % SMYS if I don’t know material? How long can an operator report “unknown” for
material? ......................................................................................................................................................... 10
Operation and Maintenance (O&M) Manual .................................................................................................... 11
25. 26. 27. Am I required to have an O&M manual under § 192.605 for my Types B and C gathering lines? ............... 11
Do the requirements under § 192.9 require a class location study or survey for Type C gathering lines? ..... 11
Are all gas gathering lines (including Types B and C) required to comply with 49 U.S.C. 60108, including
the self-executing provision from Section 114 of the PIPES Act of 2020? .................................................... 11
28. Do Type C gathering line operators have to comply with § 192.617 (Failure Investigation) requirements
described in § 192.615 (Emergency Plans)? ................................................................................................... 12
29. Do I have to comply with all aspects of the “Public Awareness Programs for Pipeline Operators” from the
first edition of API RP 1162 for my Type B and C gathering lines? .............................................................. 12
30. Does § 192.615(a)(11) require a Type C gathering line operator to have procedures for control room
management in accordance with § 192.631? .................................................................................................. 13
31. Are individual service lines (i.e., farm taps) that are connected to a Type C gathering line subject to the
requirements of § 192.740? ............................................................................................................................ 13
Compressor Stations ............................................................................................................................................. 13
32. 33. Do the new Type C regulations apply to compressor stations or other facilities? .......................................... 13
If the pipes entering and leaving a compressor station are regulated as Type C gathering lines, how do I
determine what requirements apply to the compressor station? ..................................................................... 14
Operator Qualification ......................................................................................................................................... 14
34. Am I required to have qualified staff per subpart N perform covered operations and maintenance tasks on
my Type B or C gas gathering line? ............................................................................................................... 14
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General
1. What is a gathering line?
Gathering lines transport gases and hazardous liquids from a production facility to a processing facility,
refinery, or a transmission line. In the past, most gathering lines were built in minimally populated areas,
used smaller-diameter pipelines that operated at lower pressures, and appeared to pose a much lower risk
than for other types of pipelines. As our nation continues to grow, our populations are spreading to these
once-rural locations, and an increased demand for natural resources means exploring alternate methods of
producing raw materials that may come with greater risk. PHMSA issued the “Safety of Gas Gathering
Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other
Related Amendments” final rule in November 2021 (final rule; 86 FR 63266). This rule extended pipeline
safety regulations to a subset of gas gathering lines of increased diameter and pressure—often located in
rural areas—with safety and environmental risks commensurate with the risks posed by gas transmission
pipelines long subject to PHMSA safety regulations.
2. Who regulates gathering lines?
Both the Federal Government and states have jurisdiction over gathering lines. PHMSA regulates gas
gathering lines and hazardous liquid gathering lines. PHMSA establishes the minimum safety and
reporting requirements for regulated gas and hazardous liquid gathering lines.
These FAQs are focused on safety and reporting requirements for Types C and R onshore gas gathering
lines. In November 2021, PHMSA published a final rule (86 FR 63266), which expanded the scope of
federally-regulated gas gathering lines; PHMSA subsequently published technical corrections to the final
rule (87 FR 26296; 87 FR 35675). Operators of gathering lines regulated by a state authority should
consider the applicable state’s safety and reporting requirements that may apply to their gathering lines, as
states may, in some circumstances, adopt additional or more stringent safety standards. In the federal
pipeline safety regulations, a gas “pipeline” includes all parts of those physical facilities through which
gas moves in transportation, including pipe, valves, and other appurtenance attached to pipe, compressor
units, metering stations, regulator stations, delivery stations, holders, and fabricated assemblies.
3. Are all gas gathering lines regulated by PHMSA?
Yes, however not all gas gathering lines are subject to part 192. PHMSA introduced new definitions in 49
CFR 191.3 and 192.8(c) that are relevant to the regulatory status of onshore gas gathering lines:
“regulated onshore gathering” and “reporting-regulated gathering.” Types A, B, and C gas gathering lines
are onshore gas gathering lines subject to requirements under parts 191 (reporting) and 192 (safety), so
the gathering lines in these categories are defined as “regulated onshore gathering;” while Type R are
subject to limited reporting requirements under part 191 only and are called “reporting-regulated
gathering.” Note that the classification (Type A, B, C, or R) for an onshore gas gathering line is
determined in accordance with § 192.8. Offshore gathering lines are also subject to parts 191 and 192
requirements as specified in § 192.9.
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4. What is a regulated onshore gathering line within the inlets of the
Gulf of Mexico?
A regulated onshore gathering line in § 192.8(c) includes a qualifying gathering line located within the
inlets of the Gulf of Mexico in waters up to 15 feet deep. See 49 CFR 192.1(b)(4), 192.3. If the pipeline is
in the Gulf of Mexico in waters greater than 15 feet, it is an offshore gathering line.
Section 192.3 defines the “Gulf of Mexico and its inlets” as “the waters from the mean high water mark
of the coast of the Gulf of Mexico and its inlets open to the sea (excluding rivers, tidal marshes, lakes, and
canals) seaward to include the territorial sea and Outer Continental Shelf to a depth of 15 feet (4.6
meters), as measured from the mean low water.”
5. How do you calculate PIR if you are not obligated to establish an
MAOP pursuant to § 192.9(e)(ii)?
The maximum allowable operating pressure (MAOP) of a pipeline is an input to the threshold
determination pursuant to § 192.8 that a facility is a Type C gathering line. When no MAOP has
previously been calculated for a given gas gathering line and the operator is not obliged to establish an
MAOP pursuant to § 192.9(e)(2)(ii), an operator may make that threshold determination using one of two
methods. First, the operator may calculate an MAOP consistent with the methods at § 192.619(a) or
(c)(1). Alternatively, as a substitute for MAOP, an operator may use the highest operating pressure to
which the segment was subjected during the preceding five years. See 49 CFR 192.8(c)(4). PHMSA
clarified this method for operators without an available MAOP in a technical correction to the final rule,
which issued May 4, 2022 (87 FR 26296).
The pressure value, identified using one of the two methods above, may also be used to inform whether a
Type C gathering line of 16 inches in diameter or less is exempt from certain regulatory requirements
under § 192.9(f)(1), because MAOP is an input in determining the potential impact radius (PIR) and
potential impact circle pursuant to § 192.903. (Note that the PIR calculation for gathering lines requires
the use of a 0.73 gas factor). See 49 CFR 192.9(f)(1). For this determination under § 192.9(f)(1), an
operator calculates the potential impact circle using their MAOP, or “[i]f the gathering line segment does
not have an established MAOP or other records necessary to perform the PIR calculation, the operator
may perform the same determination on a class location unit (see § 192.5) basis rather than a potential
impact circle basis.” 86 FR at 63283; 49 CFR 192.9(f)(1)(ii). The class location unit method for applying
these exceptions is also used in API RP 1182 (First Ed., 2020) and provides a simpler, more conservative
method for determining the applicability of the § 192.9(f) exception for operators that choose not to
perform a PIR analysis or lack records of the parameters necessary to calculate the PIR.
A class location unit is one mile in length and extends 220 yards on either side of the centerline of a
pipeline, using a “sliding mile” approach. See 49 CFR 192.5. The class location unit moves along the
pipeline, and if the sliding mile contains a building intended for human occupancy or other impacted site
at any point during the mile’s movement, then the exception in paragraph (f) does not apply for the entire
mile of pipeline contained within the sliding mile.
6. What constitutes a “building intended for human occupancy or
other impacted site” in § 192.9(f)?
In § 192.9(f)(3), PHMSA defines the term “building intended for human occupancy or other impacted
site” to include any of the following:
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• Any building that may be occupied by humans, including homes, office buildings, factories,
outside recreation areas, plant facilities, etc.;
• A small, well-defined outside area (such as a playground, recreation area, outdoor theater, or
other place of public assembly) that is occupied by 20 or more persons on at least 5 days a
week for 10 weeks in any 12-month period (the days and weeks need not be consecutive).
This has the same meaning and interpretation as the Class 3 criterion in § 192.5(b)(3)(ii); or
• Any portion of the paved surface, including shoulders, of a designated interstate, other
freeway, or expressway, as well as any other principal arterial roadway with 4 or more lanes,
as defined in the Federal Highway Administration’s Highway Functional Classification
Concepts, Criteria, and Procedures, section 3.1 (2013 Ed.),
https://www.fhwa.dot.gov/planning/processes/statewide/related/highway_functional_classific
ations/fcauab.pdf. See 86 FR at 63288; 49 CFR 192.3.
7. When using method 2 in § 192.9(f)(1)(ii), can an operator of a
Type C gas gathering line “cluster” buildings intended for human
occupancy as allowed in § 192.5?
No. Section 192.9(f)(1)(ii) provides exception from certain requirements for gathering lines that are 16
inches or less and not within a class location unit containing a building intended for human occupancy or
other impacted site. Section 192.5 defines the class location unit and paragraph (c)(2) allows an operator
to adjust the length of a class 2 or class 3 location based on the position of the last building intended for
human occupancy within a group of structures. This is commonly referred to as “clustering.” PHMSA did
not, in either the final rule text or its preamble, explicitly provide for “clustering” to adjust the boundaries
of Class 1 locations, as it did in other contexts (see §§ 192.5(c) and 192.8(c)(2)). As Type C gathering
lines occur only in Class 1 locations, the concept of “clustering” is not applicable for Type C gathering
lines to determine whether they fit within the exception in § 192.9(f)(1)(ii) either.
8. Am I required to maintain records for my Type B and Type C
gathering lines?
Yes, where specified or necessary to evidence compliance with a regulation. In general, a person owning
or operating a gas pipeline facility is required to maintain records, make reports, and provide information
to PHMSA upon request in accordance with 49 U.S.C. 60117(c). Owners and operators must make and
maintain records in accordance with the requirements prescribed in 49 CFR parts 191 and 192 to enable
PHMSA to verify that the owner or operator is complying with those requirements. Certain records are
maintained for a specific length of time while others are required to be maintained for the life of the
pipeline. PHMSA uses these records to verify compliance with regulated safety standards and to inform
the Agency on possible safety risks.
For example, the final rule adds a new requirement in § 192.8(b) to specify that all onshore gas gathering
line operators must maintain records documenting the methodology used to determine the beginning and
endpoints of segments determined to be gas gathering lines. In addition, § 192.9(e)(2)(ii) requires
operators of Type C gathering lines greater than 12.75 inches in outside diameter to maintain records used
to establish the MAOP for the life of the pipeline. Furthermore, operators of Type B and certain Type C
gathering lines are required to comply with the corrosion control requirements of subpart I, including
§ 192.491, which provides specific corrosion control record keeping requirements that operators must
comply with. See 49 CFR 192.452(b)-(c).
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Finally, where a regulatory requirement does not have an explicit records retention requirement, records
nonetheless may be necessary to show compliance with the pipeline safety regulations during an
inspection.
Reporting Requirements
9. What are my reporting requirements for Type R lines?
Incident reports under § 191.15 and annual reports under § 191.17 are required for all onshore gas
gathering lines, including Type R gathering lines. Safety-related condition reports under § 191.23,
however, are not required for any Type R gathering lines as well as certain Type C gathering lines that are
not required to determine a maximum allowable operating pressure (MAOP) under § 192.619.
Additionally, all onshore gathering lines, including Type R gathering lines, are required by § 191.5 to
submit immediate notification of incidents and, under § 191.22, to meet the applicable requirements to
acquire an operator identification number (OPID). Operators should consider any applicable state
reporting requirements that may apply.
10. Are gathering lines operating at less than 0 psig considered Type
R?
Yes, incident reports and annual reports will now be required for all onshore gas gathering lines,
including Type R gathering lines operated at less than 0 pounds per square inch gauge (psig). As stated in
its preamble, the final rule revised § 191.1(b) to remove the exception to part 191 in § 191.1(b)(4) for
unregulated, onshore gas gathering lines, including gathering lines that operate at less than 0 psig or are
located within the inlets of the Gulf of Mexico.
11. Am I required to obtain an operator identification number (OPID)
for reporting-regulated gas gathering lines (i.e., Type R)?
Yes, operators of all gas gathering lines, including Type R lines, must obtain an OPID under § 191.22(a).
The final rule, in § 191.1(c)(2), excepts Type R gas gathering lines from OPID validation and notification
requirements in § 191.22(b) and (c). However, the accident and incident form instructions require
operators of all gas gathering lines, including Type R lines, to ensure the accuracy of any OPID
information (e.g., primary entity, name) submitted to PHMSA in connection with an incident or annual
report.
12. Are Type R gas gathering lines required to notify PHMSA of flow
reversals lasting more than 30 days under § 191.22(c)(1)(v)?
No. Section 191.1(c)(2) exempts onshore Type R gathering lines from § 191.22(c). However, PHMSA
guidance on flow reversals and conversions of service is available at
https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/guidance-pipeline-flow-reversals-
product-changes-and-conversion-to-service.
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13. Can I file my type R annual report along with my other gathering
lines?
Annual reports for Types A, B, C, and offshore gathering lines (along with appropriate transmission lines)
can be filed with a single annual report on DOT Form PHMSA F7100.2-1. Type R annual reports are
required to be filed using DOT Form PHMSA F7100.2-3, available on PHMSA’s website at
https://www.phmsa.dot.gov/forms/operator-reports-submitted-phmsa-forms-and-instructions.
14. Are individual service lines (i.e., farm taps) directly connected to
Type R gathering or production pipelines required to be reported
on a distribution annual report?
Although a service line is regulated by parts 191 (reporting) and 192 (safety), an individual service line
directly connected to Type R gathering and production lines is exempted from being reported on a gas
distribution annual report, per § 191.11(b).
Construction requirements
15. Must all existing pipelines that have been newly identified as Type
C gathering lines pursuant to the final rule issued in November
2021 be retrofitted to meet its design and construction
requirements?
No. Only Type C gathering lines that are installed, replaced, relocated, or otherwise changed after May
16, 2022, must meet the design and construction requirements adopted in the November 2021 final rule.
See 49 CFR 192.9(e)(1)(i) and (g)(4).
16. When has a pipeline been “otherwise changed” for the purpose of
the applicability of certain design, construction, initial inspection,
and testing requirements that PHMSA has adopted since initial
construction of the pipeline?
Certain regulations apply to pipelines that are new, replaced, or otherwise changed. For example, see
§§ 192.8(a)(5) and 192.9(d)(1), (e)(1)(i) and (g). PHMSA has explained that “otherwise changed” refers
to a substantial physical alteration of a pipeline facility as opposed to a repair or restoration.” (71 FR
13289, 13298 (Mar. 15, 2006)). A similar definition is contained in the ANSI/GPTC Z380.1, GPTC
Guide for Gas Transmission, Distribution, and Gathering Piping Systems.1
Whether a gas pipeline has been “otherwise changed” depends upon the specific nature of the alteration,
including when the original alignment or functionality of the pipeline facility is modified by the
alteration. Examples of a substantial physical alteration that should be considered to satisfy “otherwise
1 Gas Piping Technology Committee Z380, “The Guide for Gas Transmission, Distribution and Gathering Piping
Systems,” ANSI GPTC Z380.1-2022, at 25 (Mar. 2022).
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changed” may include the following: (a) addition of a pig launcher or receiver to a pipeline; (b) relocation
of a pipeline; or (c) connection of a lateral.
17. Is overpressure protection required on my Type C gathering line?
Yes, new, relocated, replaced, or otherwise changed Type C gathering lines, which are required to have
overpressure protection as encompassed in the design, installation, construction, initial inspection, and
initial testing provisions, must comply with subparts B though G and J of part 192. Overpressure
protection regulations that apply to the pipeline may vary, and may include §§ 192.143, 192.169,
192.195, among other regulatory requirements. These overpressure protection requirements would not
apply, however, to pipeline segments 40 feet or shorter in length that are replaced, relocated, or changed
on a pipeline existing on or before May 16, 2022. 49 CFR 192.9(f)(2).
In addition, certain Type C gathering lines are required to establish an MAOP in accordance with
§ 192.9(e)(2)(ii). For those lines that are required to establish their MAOP, exceeding that established
MAOP (plus the margin or build-up) must be reported as a safety-related condition under § 191.23(a)(6)
and (b)(1).
Operators of existing gathering lines that became regulated as Type C gathering lines as a result of the
2021 final rule are not required to retroactively comply with the design, installation, construction, initial
inspection, or initial testing requirements of part 192—including overpressure protection requirements at
§§ 192.143, 192.169, 192.195. They are, however, required to prevent and to report MAOP exceedances
if required to establish an MAOP pursuant to § 192.9(e)(2).
18. Are Type C plastic pipe gathering lines subject to the design,
installation, construction, and initial inspection requirements in
subparts B though G and J of part 192 applicable to transmission
lines?
Yes, § 192.9(e)(1)(i) requires operators of all Type C gathering lines installed after May 16, 2022, to
follow the design, installation, construction, initial inspection, and initial testing requirements in subparts
B though G and J of part 192 applicable to transmission lines (although compliance with §§ 192.67,
192.127, 192.179(e), 192.179(f), 192.205, 192.227(c), 192.285(e), 192.506, 192.634, and 192.636 is not
required). This includes all Type C plastic pipe that is new, replaced, or otherwise changed after May 16,
2022.
Type C plastic pipes with an outside diameter greater than 12.75 inches have additional requirements.
Section 192.9(e)(2) specifies that those larger diameter plastic pipes must comply with all the
requirements of § 192.9(e)(1) and establish an MAOP, among other requirements.
19. For pipe made with composite materials, is notification under
§§ 192.9(h) and 192.18 required for replacement, relocation, or
changes of 40 feet or less of composite pipe?
It depends on the installation date of the pipeline and the material used in the replacement. For all Type C
gathering lines (including composite pipelines) installed prior to May 16, 2022, notification to PHMSA is
not required for “pipeline segments 40 feet or shorter in length that are replaced, relocated, or changed,”
per § 192.9(f)(2). See 86 FR at 63289.
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In addition, the final rule also allows the future use of composite pipe material on Type C gathering lines
in certain circumstances, subject to PHMSA notification pursuant to § 192.18 of the replacement,
relocation, or other significant change to the pipe. See 86 FR at 63289. That notification is required
regardless of pipe segment length. In other words, replacement or other significant change of a pipe
segment on a Type C gathering line that was installed after May 16, 2022, using composite material
requires a notification to PHMSA under §§ 192.9(h) and 192.18 regardless of the segment length. An
operator may consider including in its initial §§ 192.9(h) and 192.18 notification its proposed procedures
for future replacement or other significant change on all segments.
If an operator discovers a condition that requires immediate replacement, operators should describe all
urgent conditions in their § 192.18 notification or conduct the repair using materials authorized under part
192, such as steel. Alternatively, they may describe those urgent conditions in their request for a state
waiver per 49 U.S.C. 60118(e) or request an emergency special permit under § 190.341.
20. What are the requirements for composite Type C pipelines
installed prior to the effective date of the rule?
Composite pipelines that were installed and in operation prior to the effective date of the final rule, May
16, 2022, are not subject to the design, installation, construction, initial inspection, or initial testing the
requirements in subparts B though G and J of part 192 applicable to transmission lines. As stated in the
preamble to the final rule, “operators may continue to use composite pipe [or materials] installed on or
before the effective date of the rule; no notification under §§ 192.9(h) and 192.18 would be required in
those circumstances.” 87 FR at 63285. However, operators of all Type C gathering lines—including
composite Type C lines installed and in operation prior to May 16, 2022—must comply with all other
applicable Type C requirements by the relevant compliance deadlines. Section 192.9(h) governs use of
composite materials for Type C gathering lines installed after May 16, 2022.
Design Requirements
21. Does an operator need to establish an MAOP for determining Type
C gathering lines?
No, an operator is not required to establish an MAOP prior to determining the endpoints of their Type C
gathering lines. Section 192.8(c)(4) provides that gas gathering line operators may use either of two
methods to identify whether a gathering line qualifies as a Type C gathering line. First, an operator may
use an MAOP calculated consistent with the methods at § 192.619(a) or (c)(1). Alternatively, as a
substitute for MAOP, an operator may use the highest operating pressure to which the segment was
subjected during the preceding five years.
Once an operator of a pipeline subject to § 192.619 establishes an MAOP, the pipeline must be operated
at or below that limit. See 49 CFR 192.619(a). PHMSA encourages operators to determine and maintain a
safe operating pressure with reasonable safety factors based on known design, material, testing records,
and the operating and maintenance history of the pipeline regardless of whether establishing an MAOP is
required for that segment.
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22. Can existing records be used to establish the MAOP of Type C
gathering lines with an outside diameter greater than 12.75 inches
instead of using the highest actual operating pressure to which the
segment was subjected during the five years (60 months) preceding
May 16, 2023, or five years (60 months) before first becoming
subject to the rule, whichever is later?
Yes, for Type C gathering lines existing on or before May 16, 2022. Type C gathering lines with an
outside diameter greater than 12.75 inches are required to establish the MAOP of the pipeline and
maintain records used to establish the MAOP for the life of the pipeline. See 49 CFR 192.9(e)(2)(ii).
Those Type C gathering lines required to establish an MAOP must, per § 192.619(a)(3)(ii), operate at a
pressure not to exceed the highest actual operating pressure to which the pipe segment was subjected
during the previous five years, measured from a) May 16, 2023, or b) a later date when the line becomes a
regulated onshore gathering line. For those Type C gathering lines existing before May 16, 2022,
§ 192.619(c)(2) provides that if an operator cannot determine the actual operating pressure of
the pipeline for the five years preceding May 16, 2023, the operator may establish MAOP using other
criteria, with PHMSA notification in accordance with § 192.18. Under this process, the operator would
propose an MAOP based on the information available about the pipeline, such as actual highest operating
pressure, operational and maintenance history, pressure test records, and information about the design and
material properties of the pipeline. The operator must notify PHMSA to avail itself of this provision.
Section 192.619(c)(2) specifies the minimum information required to be submitted to PHMSA in the
notification.
23. What is the length of time required to hold a “highest actual
operating pressure” to claim that pressure as the MAOP for a
gathering line under § 192.619(a)(3) or (c)?
Several methods for making the threshold determination identifying a Type C gathering line involve
determining the highest operating pressure over a five-year period. 49 CFR 192.8(c)(4). That operating
pressure may also be relevant for Type C gathering lines required to establish an MAOP. 49
CFR 192.9(e)(2)(ii).
Neither § 192.619(a)(3) (c), nor § 192.8(c)(4)(ii) specify a minimum hold time for identification of the
highest operating pressure over a five-year period, but the operating pressure must be documented.
Documentation methods include electronic (e.g., supervisory control and data acquisition system) or
hardcopy records of pressure readings on the segment of pipe. MAOP records must be retained for the life
of the pipeline until it is properly abandoned or removed in accordance with § 192.619(f). For additional
provisions applicable for Type C gathering lines, reference § 192.619(c)(2).
24. How do I calculate % SMYS if I don’t know material? How long
can an operator report “unknown” for material?
Section 192.107(b)(2) allows an operator to use a default specified minimum yield strength (SMYS) of
24,000 psi if the yield strength of a pipe is not known. Operators may report unknown material in their
required reporting for an indefinite timeframe.
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Operation and Maintenance (O&M) Manual
25. Am I required to have an O&M manual under § 192.605 for my
Types B and C gathering lines?
There is no explicit requirement in the Federal pipeline safety regulations for operators of Type B or C
gathering lines to have § 192.605-compliant O&M manuals. See 49 CFR 192.9(d) and (e). Nevertheless,
operators of all gas gathering lines subject to part 192 safety requirements, including Types B and C
gathering lines, are required to follow the statutory requirement of 49 U.S.C. 60108(a), which requires
that “[e]ach person owning or operating a gas pipeline facility. . . shall carry out a current written plan
(including any changes) for inspection and maintenance of each facility used in the transportation and
owned or operated by the person. A copy of the plan shall be kept at any office of the person the Secretary
of Transportation considers appropriate. The Secretary also may require a person owning or operating a
pipeline facility subject to this chapter to file a plan for inspection and maintenance for approval.”
In addition, operators of Types B and Type C gathering lines are required to comply with other regulatory
provisions that require specific written plans, programs, and procedures. For example, Types B and C
gathering lines are required to comply with public education program requirements in § 192.616(a),
which states that “each pipeline operator must develop and implement a written continuing public
education program that follows the guidance provided in the American Petroleum Institute’s (API)
Recommended Practice (RP) 1162.
”2 Therefore, an operator of a Type B or C gathering line must have a
written public education program even though they do not fall under the more general requirement in
§ 192.605 to have an O&M manual.
26. Do the requirements under § 192.9 require a class location study or
survey for Type C gathering lines?
No, operators of Type C gathering lines are not required to comply with the requirements of § 192.609.
However, operators of Type C gathering lines are required to understand the area in which their pipelines
are located. Section 192.9 at subparagraphs (g)(3) and (g)(5) require operators of Type C (as well as Type
R) gathering lines to be aware of information that may lead to a class location change, such as dwelling
density and MAOP increases. Section 192.452(c) similarly contains requirements for operators of Type C
gathering lines to be aware of information that may lead to a class location change. Additionally, certain
regulatory requirements, such as leakage surveys and other inspections, require operators to periodically
access the pipeline right-of-way where changes in class location would be apparent.
27. Are all gas gathering lines (including Types B and C) required to
comply with 49 U.S.C. 60108, including the self-executing
provision from Section 114 of the PIPES Act of 2020?
Section 114 of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020
amended the pipeline safety statues at 49 U.S.C 60108. Section 60108(a)(1) requires each person owning
or operating a gas or hazardous liquid pipeline facility to carry out a written inspection and maintenance
plan.
2 API, Recommended Practice 1162, “Public Awareness Programs for Pipeline Operators,” (1st Ed. Dec. 2003)
(“API RP 1162”).
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49 U.S.C. 60108(a)(2)(D) requires that pipeline facility operators’ inspection and maintenance plans
address the elimination of hazardous leaks and minimization of releases of natural gas (including, and not
limited to, intentional venting during normal operations) from their systems. As detailed in PHMSA
Advisory Bulletin ADB-2021-01, this requirement is self-executing, meaning it applies even absent a
codifying regulation.3
Owners and operators of offshore and regulated onshore gathering lines (Types A, B, and C gathering
lines) are subject to the requirements in 49 U.S.C. 60108. See 49 U.S.C. 60101(a)(3) and 60101(a)(21);
49 CFR 192.8(c) and 192.9(b). Because § 192.8(c)(3) specifies that Type R gathering lines are not subject
to part 192 safety requirements, they are not “regulated gathering lines” subject to 49 U.S.C. 60108.
Operators of offshore and onshore regulated gathering lines are required to have written inspection and
maintenance plans in accordance with 49 U.S.C. 60108 and update those plans in accordance with the
requirements of 49 U.S.C. 60108(a)(2)(D)).
28. Do Type C gathering line operators have to comply with § 192.617
(Failure Investigation) requirements described in § 192.615
(Emergency Plans)?
No. W
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