{"operation":"document","citation":"PI-23-0020","title":"Hanna Oil and Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2024-06-10","effective_on":null,"summary":"PI-23-0020 response to Hanna Oil and Gas Company concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-23-0020.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-23-0020.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-23-0020","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-06/Hanna-PI-23-0020-06-10-2024-Part192.1.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration June 10, 2024\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMr. Sam Hanna\nPipeline Operations Manager\nHanna Oil and Gas Company\n60 S 6th Street\nFort Smith, AR 72901\nDear Mr. Hanna:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated\nOctober 3, 2023, you requested an interpretation of the Federal pipeline safety regulations in\n49 Code of Federal Regulations (CFR) Part 192 with respect to a change in classification of an 8-\ninch diameter natural gas pipeline in Arkansas from a transmission line to a gathering line.\nYou stated Hanna Oil and Gas Company’s Arkoma Main Sales 8-inch diameter pipeline directly\nconnects to Enable “Line O” Transmission pipeline 8.3 miles away from your central compressor\nstation. You also stated that the Arkoma Main Sales 8-inch diameter pipeline was installed in\nOctober of 2001. In addition, you provided your pipeline layout on aerial photos and referred to\nthe latest definitions from American Petroleum Institute (API) Recommended Practice (RP) 80\nSecond Edition (March 2020).1 You stated this pipeline is currently classified as a Class 1\nlocation transmission pipeline under Part 192 regulations. You asked, based on the November\n15, 2021, Gas Gathering Pipelines final rule, whether this pipeline should be regulated as a Type\nC regulated gas gathering pipeline.\nTo respond to your request, the current, relevant portions of §§ 192.8 and 192.9 are reprinted\nbelow:\n§ 192.8 How are onshore gathering pipelines and regulated onshore gathering pipelines\ndetermined?\n§ 192.8(a)(4) The endpoint of gathering, under section 2.2(a)(1)(D) of API RP 80, may\nnot extend beyond the furthermost downstream compressor used to increase gathering\nline pressure for delivery to another pipeline.\n§ 192.8(a)(5) For new, replaced, relocated, or otherwise changed gas gathering pipelines\ninstalled after May 16, 2022, the endpoint of gathering under sections 2.2(a)(1)(E) and\n2.2.1.2.6 of API RP 80 (incorporated by reference, see § 192.7)—also known as\n1 1st edition (April 2000) of API RP 80 is incorporated by reference in Part 192\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\nPage 2 of 3\n“incidental gathering”—may not be used if the pipeline terminates 10 or more miles\ndownstream from the furthermost downstream endpoint as defined in paragraphs\n2.2(a)(1)(A) through (a)(1)(D) of API RP 80 (incorporated by reference, see § 192.7) and\nthis section.\n§ 192.8(c) For purposes of Part 191 of this chapter and § 192.9, the term “regulated\nonshore gathering pipeline” means:\n(1) Each Type A, Type B, or Type C onshore gathering pipeline (or segment of onshore\ngathering pipeline) with feature described in the second column of table 1 to paragraph\n(c)(2) of this section that lies in an area described in the third column;\nType C onshore gathering pipeline:\nOutside diameter greater than or equal to 8.625 inches and any of the following:\n—Metallic and the MAOP produces a hoop stress of 20 percent or more of SMYS;\n—If the stress level is unknown, segment is metallic and the MAOP is more than 125\npsig (862 kPa); or\n—Non-metallic and the MAOP is more than 125 psig (862 kPa)\n§ 192.9 What requirements apply to gathering pipelines?\n§ 192.9 (e) Type C lines. The requirements for Type C gathering lines are as follows:\n(1) An operator of a Type C onshore gathering line with an outside diameter\ngreater than or equal to 8.625 inches must comply with the following\nrequirements:\n(i) Except as provided in paragraph (h) of this section for pipe and components\nmade with composite materials, the design, installation, construction, initial\ninspection, and initial testing of a new, replaced, relocated, or otherwise changed\nType C gathering line, must be done in accordance with the requirements in\nsubparts B through G and J of this part applicable to transmission lines.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nPage 3 of 3\nThe Arkoma Sales 8-inch diameter, 8.3 miles long pipeline is not subject to the limitation of\nincidental gathering in 192.8(a)(5). The pipeline meets the end point and mileage requirements\nof §§ 192.8(a)(4) and 192.8(a)(5). The pipeline is in Class 1 location. Assuming that the central\ncompressor station is the furthermost downstream endpoint of gathering as defined in§ 192.8(c)\nand API RP 80, 1st Edition, the Arkoma Main Sales 8-inch diameter, and 8.3 miles long pipeline\nmay meet the definition of an incidental gathering pipeline as a Type C regulated onshore\ngathering pipeline and then must comply with the requirements at § 192.9(e) for Type C lines.\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJohn A. Gale\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING • FORT SMITH, ARKANSAS 72902\n479-782-8808 • FAX 479-782-1343\nOctober 3rd\n, 2023\nAttn: John Gale\nPipeline and Hazardous Materials Safety Administration\nOffice of Standards and Rulemaking\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nUnited States\nRE: Hanna Oil and Gas Co. Request for Written Regulatory Interpretation\nHanna Oil and Gas Co. is requesting a written regulatory interpretation on one of its natural gas\npipelines in Arkansas being the Arkoma Main Sales 8 inch line which is currently classified as a Class 1\nTransmission pipeline, relative to the following reporting and regulations:\n1.)49 CFR Part 192 Gas Gathering Line Definition for Onshore Gas Gathering lines and Pipeline\nSafety:\n2.) Safety of Gas Gathering Pipeline; Extension of Reporting requirement\n3.) Regulation of Large, High-Pressure Lines, and Other Related Amendments\n4.) New Safety Standards, Final Rule,\n5.) Federal Register, Vol 86, No. 217 November 15, 2021,\n6.) The Latest Definitions in API RP 80 March 2020.\nBased on the above referenced regulations and according to the definition of API RP 80, The Arkoma\nMain Sales 8 inch line would be considered Type C incidental Gathering line on May 16th\n, 2022.\nAs illustrated in Figure 2-6 of section 2.2.1.2.6 of API RP -80, In the case of gas processing or gas\ntreatment, the connection to a transmission line is generally contained within the boundaries of the\nfacility. This is not always the case, however. The gathering line operator may have to move the gas\nthrough a pipeline some additional distance from the plant to another pipeline. The pipeline moving the\ngas from the plant to another pipeline is termed \"incidental gathering.\" The \"incidental gathering''\nresumes at the plant outlet and continues to the other pipeline connection.\nHanna O&G gathering endpoint is the Central Compressor Station. The 8 inch Arkoma Main Sales line\nthen directly connects to the Enable \"Line O\" Transmission line a distance of 8.3 miles away, therefore\nconnecting \"incidental gathering\" line with the endpoint of gathering being its connection with the\ndownstream Enable \"Line O\" Transmission line (See attached schematic of the Arkoma Gathering\nSystem).\n\n<<<PAGE 5>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING 479-782-8808 •\n• FORT SMITH, ARKANSAS 72902\nFAX 479-782-1343\n2.2.1.2.6 Incidental Gathering\nIn the case of gas processing or gas treatment. the connec-\ntion to a transmission line is generally oontaincd within !he\nboundaries of the facility. lhis is not always the case, how•\never. The gathering tine operator may have to move the gas\nthro a pipeline some additional distance from the plant to\nanother pipeline. The pipeline moving the gas from the plant\nto another pipeline is tenned \"'incidental gathering.\" 1he\n.. incidental gathering'\" resumes at the plant outlet and contin-\nues to lhe other pipeline connection. Incidental gathering may\nalso occur when a compressor is a potential endpoint lnci-\ndtntal gathering normally is present when the point of last\ncommingling is the last \"identified endpoint.- From a func-\ntional standpoint. this section of incidental gathering line is\nno different from the rest of the gathering system. The defini-\ntion. therefore. includes reciognition that gathering may con-\ntinue downstream of the last endpoint identified by\nprocessing, treatment, commingling. or compression activi-\nties to the cormcction with another pipeline. Figure 2-6 illus-\ntrates this concept\nFurthermost\nDownstream\nPoint\nin Produdion\nOperation\n.--- ---. / Production Furthermost Downstream Gas\nProcessing Plant, Gas Treatmeot\nOperation ..,__...,. Facility, Gas Compression, or ..... _ .... .,...\nPoint of Last Commingling\n\"Incidental gathering\" is the\nadditional do stream\ngathering piperne sometimes\nneeded to connect the outlet\nof an idenbf ted gmheting\nendpoint with a transmission\nline, distribution line, or other\npipeline facility.\nGathering\nFunction\nFigure 2-6-lncidental Gathering Downstream of an Identified Endpoint\nBased on previous PHMSA interpretations (Pl-009-0008 July 30, 2009) and (Pl-09-0002 July 14, 2009)\nincidental gathering designations were permissible due to what was considered a drafting error. To\nHanna Oil & Gas's knowledge, no other related rulemaking has been issued until the November 2021\npublication of the final gas gathering rule. Hanna's understanding of Safety of Gas Gathering Pipelines:\nExtension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and other related\nAmendments, New Safety Standards, Final Rule Federal Register, Vol. 86, No. 217 is that the incidental\ngathering concept as described in API RP-80 may not be used for new, replaced, relocated, or otherwise\nchanged gas gathering line installed after the effective date of the final rule (May 16, 2022) if the\nendpoint in 10 miles or more from the furthest downstream point where a gathering line begins as\ndetermined in paragraphs 2.2(1)(1)(A) through (a)(l)(D) of API RP-80. Incidental gathering lines existing\non or before the effective date of the rule may continue to operate as a gathering line, regardless of\nlength. The Arkoma Main Sales 8 inch line was installed in October of 2001, existing prior to the final\nrule.\nPHMSA Final Rule\n\n<<<PAGE 6>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING • FORT SMITH, ARKANSAS 72902\n479-782-8808 • FAX 479-782-1343\nVol 86 No 217 provides the following new rule definition/guidelines:\n192.8 How are onshore gathering pipelines and regulated onshore gathering pipelines determined?\n192,S(a)(S) For new, replaced, relocated, or otherwise changed gas gathering pipelines installed\nafter May 16, 2022, the endpoint of gathering under sections 2.2(a)(l)(E) and 2.2.1.2.6 of API RP 80\n(incorporated by reference, see§ 192.7)-also known as \"incidental gathering\"-may not be used if\nthe pipeline terminates 10 or more miles downstream from the furthermost downstream endpoint as\ndefined in paragraphs 2.2(a)(l)(A) through (a)(l)(D) of API RP 80 (incorporated by reference, see§\n192.7) and this section. If an \"incidental gathering\" pipeline is 10 miles or more in length, the entire\nportion of the pipeline that is designated as an incidental gathering line under 2.2(a)(l)(E) and 2.2.1.2.6\nof API RP 80 shall be classified as a transmission pipeline subject to all applicable regulations in this\nchapter for transmission pipelines.\nBased on the final rule, Hanna Oil & Gas Co considers the Arkoma Main Sales 8 inch line which is\ncurrently regulated as a transmission pipeline, as a \"regulated incidental gathering line\" under Type C\ndesignation. Hanna Respectfully requests a written regulatory interpretation of its determination that\nthe Arkoma Main line as of May 16, 2022, is a regulated Type C Incidental Gathering Line following the\nguidelines for determining Class 1 lines are under 10 miles and metallic and the MAOP produces a hoop\nstress of 20 percent or more of SMYS. The MAOP of the Arkoma Line is 1318 while 100% SMYS is 1831.\nThe MAOP is 72% of SMYS. The avg operating pressure of the line is 740psig. Hanna Oil & Gas Co. is\nmaking this request based on the suggestion of the Arkansas Oil & Gas Commission, as the commission\nhas not concluded an exact determination for the pipeline.\nPlease call me at 479-651-7578 with any questions regarding this request.\nThank you,\nSam Hanna\nPipeline Operations Manager\nHanna Oil & Gas Co\n60 S 6th st, Fort Smith, Arkansas, 72901\nPhone 479-651-7578 - Fax 479-782-1343\n\n<<<PAGE 7>>>\n\nHANNA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING\n479-782-8808\n•\n•\nFORT SMITH, ARKANSAS 72902\nFAX 479-782-1343\nArkoma Main line Schematic:\n•\n•\nProduction\nOperatlon\nCentral Compressor and\nGa the ring point\nIncidental Gathering •(Currently\nlabeled \"Transmission Pipeline\")\n• •\n•••\n8 inch diameter steel line\nYleld Strength in psi: 42000\nNominal wall thickness: .188\nMAOP Design Pressure: 1318\nOperating pressure: 700psl\nLength: 8.3 miles\n\n<<<PAGE 8>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING • FORT SMITH, ARKANSAS 72902\n479-782-8808 • FAX 479-782-1343\nThe gas for the Arkoma Main Gathering Line comes from the above wells marked by the yellow dots. All\nwells flow on suction and are brought in to the Central Compressor Station marked with a green dot at\n\n<<<PAGE 9>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING • FORT SMITH, ARKANSAS 72902\n479-782-8808 • FAX 479-782-1343\nthe \"begin Incidental Gathering\" wording. Gas enters the Central Compressor station after being\ncompressed at Pod 1, 3, and 5. It flows into the 2 compressors on site and then on to the Wet Gas Meter\nthat sits before the Ross, LLC gas inlet. Gas flows directly into the dehydrator tower where some gas is\nsent back to a Dehy Regen tower to accumulate before going to power the 2 compressors on site. After\nthe Dehydrator, gas passes through the Dry Gas Meter and then on to pass by the Pressure Relief Valve\n(PRV). The PRV has a set pressure of ll0Olbs. Gas then flows at~700Ibs and enters the 8\" steel line (red\nand blue line) that flows North to the Enable Custody Transfer point at the Enable sales meter at\nSlaytonville Interconnect. Hanna does not supply gas to any customers. The line is cathodically protected\nand has rectifier meters on both ends of the gathering line.\nCentral Compressor Station - Arkoma Main Incidental Gathering Starting Point\nHanna's Central Compressor Station is the furthermost downstream gas processing/compression point.\nFrom this location, gas flows in the 8-inch line, which has an MAOP of 1318, 8.3 miles to Enables\nTransmission Line \"O\".\n\n<<<PAGE 10>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING • FORT SMITH, ARKANSAS 72902\n479-782-8808 • FAX 479-782-1343\nSlaytonville Interconnect\nSlaytonville Interconnect is the termination point after 8.3 miles of 8-inch steel pipeline. Over the last 90\ndays, the average static pressure is 746 lbs and the average flow rate is 2,450mcf/d. The custody\ntransfer point goes into Enable's \"Line O\" line.\n\n<<<PAGE 11>>>\n\nHAN NA OIL AND GAS COMPANY\nP.O. BOX 1356 / HANNA BUILDING • FORT SMITH, ARKANSAS 72902\n479-782-8808 • FAX 479-782-1343\nType C determination\nThe Arkoma Main Gathering line meets the requirements of 49 CFR 192.9 (e).\nThe line has a nominal diameter of 8.625 inches and is metallic. Method 1 was used under 192.9(/)\nExceptions to determine Type C applicability. The segment is located within a PIR containing a single\nbuilding intended for human occupancy shown below. A PIR of 225ft was calculated as specified in\n192.903 using a factor of 0.73. The house is located at 35.09865,\n-94.43568. Arkoma Main Gathering line\nis 8.3 miles long. Classified as Class 1 with no HCA's","truncated":false,"body_characters":17162}