In the event of a pipeline failure, there is no difference between a large diameter, high pressure gathering line or transmission line.  In the event of a pipeline failure, both will act in the same fashion.

The PIR – potential impact radius is the area of greatest concern for those living near and around pipeline infrastructure.  This is the area deemed of greatest risk for loss of life and property.

PIR

While pipelines are the safest mode of natural gas transportation, not all pipelines are created equally.  Gas transmission pipelines and gas gathering pipelines in the more populated areas are regulated pipelinesRegulated gas transmission lines have Federal and State oversight.  Regulated gas gathering lines in the more populated areas have State oversight.  However, gas gathering lines in the less populated areas are exempt from Federal regulations.  The Federal government has left that jurisdiction up to the states to regulate, should they desire.  The Commonwealth of Pennsylvania up to the present time has determined not to regulate gas gathering lines in rural areas.

So, how does one know if the gas gathering line near their home is regulated?  And what does regulation mean?  A regulated gas gathering line has oversight, construction and safety/maintenance inspections through the PA PUC Gas Safety Division.  There are minimum safety standards established for items such as pipe thickness and the location of emergency shut-off valves.  Act 127 of 2011 gave the PUC jurisdiction over gas gathering in class 2, 3 and 4 area locations.

So, what are these classes all about?  The classes are defined by the Code of Federal Regulations.   The Code of Federal Regulations Title 49 Part 192.3 defines a gathering line as a “pipeline that transports gas from a current production facility [i.e. well site] to a transmission line or main.”

Class locations are based on the number of buildings intended for human occupancy that exist within a ‘‘class location unit,’’ defined as an area extending 220 yards (100 meters) on either side of the centerline of any continuous one-mile (1.6 kilometers) length of pipeline. Class locations are defined in § 192.5 as:

 

PHMSA Class Designations for Gas Pipelines

CLASS

DEFINITION

Class 1

An offshore area or any location with 10 or fewer buildings intended for human occupancy within 220 yards of the centerline of the pipeline.

Class 2

Any location with more than 10 but fewer than 46 buildings intended for human occupancy within 220 yards of the centerline of the pipeline.

Class 3

Any location with more than 46 buildings intended for human occupancy within 220 yards of a pipeline, or an area where the pipeline lies within 100 yards of either a building or a small, well-defined outside area (such as a playground) that is occupied by 20 or more persons at least 5 days a week for 10 weeks in any 12-month period.

Class 4

Any location where unit buildings with four or more stories above ground are prevalent.

 

This is where the Code exempts Class 1 Area locations.

Title 49: Transportation

§ 192.1   What is the scope of this part?

(b) This part does not apply to-

(4) Onshore gathering of gas-

(ii) Through a pipeline that is not a regulated onshore gathering line (as determined in §192.8); and (b) For purposes of §192.9, “regulated onshore gathering line” means:

So, what does this mean, Class 1 Area locations being exempt from the Federal regulations and the Commonwealth of Pennsylvania not regulating them either?  It means these Class 1 Area locations are non-jurisdictional gathering lines.  It means that no government agency, no independent agency acting on behalf of the public, has any authority to require construction standards, inspections, pipe thickness, emergency shut-off valve intervals, any oversight at all.  This also extends to gathering line infrastructure within that Class 1 Area location; a facility such as a compressor station is also non-jurisdictional when it comes to gas safety issues.

Act 127 of 2011, known as the Gas and Hazardous Liquids Pipelines Act, was signed by Governor Tom Corbett on December 22, 2011. The Act requires all pipeline operators within the Commonwealth to register with the Pennsylvania Public Utility Commission (PA PUC). A pipeline operator is defined as a person that owns or operates equipment or facilities within the Commonwealth for the transportation of gas or hazardous liquids by pipeline or pipeline facilities that are regulated under Federal pipeline safety laws. Pipelines and pipeline facilities regulated under Federal pipeline safety laws include gathering and transmission pipelines within Class 2, 3, and 4 as well as transmission pipelines within Class 1 locations. The term does not include a public utility or an ultimate consumer who owns a service line on his or her real property.  The PA PUC does not have jurisdiction over the siting of natural gas gathering lines. 

Pipeline operators in Class 1 locations that transport natural gas from unconventional gas wells are required to report the location of pipelines by class location and approximate aggregate miles to the PA PUC. This information must be updated annually. According to the PA PUC, as of October 1, 2012, 43 unconventional pipeline operators have reported a total of 2535.5 miles of unconventional pipelines. Of this, 1727.8 miles are non-jurisdictional Class 1 unconventional gathering lines, while 807.7 miles fall under the jurisdiction of the PA PUC as either Class 1 transmission or Class 2, 3, or 4 non-transmission pipelines.

[REPORT TO THE GENERAL ASSEMBLY ON PIPELINE PLACEMENT OF NATURAL GAS GATHERING LINESAs required by Act 13 of 2012; Patrick Henderson, 12/11/2012, pg. 16]

Thus, as of October 1, 2012 only 32% of the newly built Marcellus Shale unconventional gas gathering lines are regulated, the remaining, 68% of these lines are Class 1 Areas, unregulated and built by many of our homes.  And, gathering lines are continuing to be built, construction will continue for the next couple of years, with the majority of these gas gathering lines, in unregulated, non-jurisdictional Class 1 Area locations, near many of our homes.

What makes this a critical issue?  In March, 2012 the GAO released a report, PIPELINE SAFETY, Collecting Data and Sharing Information on Federally Unregulated Gathering Pipelines Could Help Enhance Safety”.  This report notes some very important facts that indicate in reality that not all gathering lines are created equal, and that regulation is indeed necessary.  Essentially, when gathering lines lack regulation, the public is dependent upon each and every operator and subcontractor working in a consistent manner that adequately addresses public health and safety.  As we see from the GAO report, not all gathering line operators, subcontractors or gathering lines are created equally, or created equally with their regulated counterparts.