That’s So Mega: What the Mega Rule Part 3 Means for Gas Gathering Lines with Mark Ryan

Rhett Alright, on this episode of pipeline things we get to get into the subject of gas gathering lines with our guest Mark Ryan. This is a highly educational episode for me, and I think it will be for our audience as well. And a bit enlightening, as we talk about a big expansion of regulations into a place that was previously unregulated. And what the differences are between regulation and integrity management. It’s a great episode we think you'll enjoy it, thanks for joining us. 00:25 Welcome to this edition of pipeline things I am your host Rhett Dotson my co-host Christopher de Leon and I am really excited about our guest today I think uh because of his college base and also just a different topic for us, Chris, as we get into the impact of the updated gas rule, part three on gas gathering line. So, audience, if you're like me, and I think my understanding of gas gathering is very, very limited. Living in the transmission space, it feels like a whole different, you know, countries, like living in the United States and now I'm going across the pond. Chris Country or state? Rhett I mean, you can have different. I think states may be more appropriate, but I think culturally. Like, you have no idea what's going on in South Dakota. Nikki is making me read a book right now called the Culture Map, which breaks up different cultures across the world. And you know, it's a funny part Americans think that there are hugely different cultures within America. There is. Yeah, but when you look at the spectrum of cultures within the United States, like from East Coast to West Coast. Every other culture, though, we're still, like, grouped together by them, right? Like, they don't say, oh, like, so for instance, if you're... Chris Well, maybe the East and West Coast might be the same, but the Third Coast is not the same. We have our own, like, entire identity. 00:20 Rhett Okay, what's that, brother? It's a third coast, bro. We got swag. Third Coast is. So, all right, well, you know what feeling like today um point is like I think culturally when we talk about gas gathering lines I feel like I'm talking to a whole different culture and so I think for our audience this is going to be very very um insightful for them uh but today you know what really shocked me is is we walked in and this is the backwards hat like series for me going like low key getting in a vibe I'll walk in and our guest is like super fly. Yeah. And I was like, okay, well. It's like gator boots and the pimped-out Gucci suit kind of line. For real, this feels like guy off the street, met guy in the business, and is now interviewing him, right? Chris I at least wore a button down collared. You weren't a bad guy, homie. Rhett This is me, though. Mark I would get heckled by my colleagues if I didn't. This is my normal. So going on a podcast and getting filmed and whatnot if I wasn't in this. Rhett Hey, we love this. Hey, I love this. This is awesome. And you know what I think that is? That's actually the first time a guest, like, self -introduced themselves before I did. So, I didn't even have a chance to introduce the guest. So, you came one. Look, our guest today is Mark Ryan. Chris Are you sure this is your show? I feel like every episode so far, your kind of losing control a little bit at a time. Rhett But you see it a little bit of control before you know it. The mark is moved all the way over. The mark is moving all the way over. So, our guest is Mark Ryan with Phillips 66 here to talk to us today, who one of my close friends described as the man. So, Mark, if you, welcome to the show first. You'll give us a little bit of background. Who is Mark Ryan? 03:38 Mark Well, you know, I've been in industry now for over 15 years. So, I actually started out as a field technician doing NDE. So, if you want to ever talk NDE, I can talk that too. Then got tired of all the travel, went over to Kiefner, cut my teeth in a lot of different things. And then got poached by DCP in the operator world. So, I've been there since. I can actually relate to you, Rhett, with the gas gathering because I started in it on liquid and gas transmission. That was my bread and butter before I got volen-told that I was going over to gas gathering to help DCP at the time, now Philip 66, work with that. So, it's a completely different world over there. And I learned quite a bit with switching over there. It's not the same as gas transmission or liquid transmission at all. 04:33 Rhett And it's really not. I mean, even in the show prep, I mean, you and Chris were blowing my mind with the difference between regulated and IM. We're talking now about the updated part three, but can you give us an elevator pitch on 30,000 ft view, on what did part 3 do for gas gathering how does it how did it regulate the landscape if you will well 05:04 Mark well i mean to put it bluntly all gas gatherings regulated now in one way shape or form yeah i mean there is no unregulated pipe anymore in gas gathering space so when people say and i i correct people all the time like oh it's unregulated no there is no unregulated gas gathering pipe period everything's regulated it's just how regulated is it Uh, so they, they pretty much the mega rule came in and in a lot of it's being driven by, uh, well, I mean, mega rule itself was driven more by safety because of San Bruno and whatnot, but the gas gathering part has been more driven about methane reduction and trying to get a handle on emissions. Uh, that's where you see some of the pipe's act of 2020. You see a lot new is coming out. Most of its spinning around emissions reductions. So, what they really were looking at for the gas gathering was how can we get a handle around reducing emissions, which is why no matter what pipe you have, you have to report your leaks and you have to have damage prevention on it. So again, trying to stop third party line strikes and everything else, which will cause releases. 06:16 Chris So, I remember back, I got to go to a lot of the GPEC meetings. I remember there was a comment. And because there's transcripts, I can't tell if it was on the record or off the record. But I remember somebody asking and saying, like, does Sims even know how many miles of gas gathering pipe there is? And that was at that time, right? We're going to talk, like, 2018, 19 timeframes, right? And so, one of the things I like to put out there is, like, a big part of the part of the, the mega rule or the new gas rule was kind of getting that, like you said, get your arms around it, right? PHMSA needed better reporting so that they could gather data. And after they gather data, then they're going to be able to think about, okay, where do we need to focus our regulatory efforts on? 06:52 Mark Correct, which is somewhat of a scary thought with getting PHMSA, you know, data, you know, all that stuff to kind of work with. Because you never know what's going to come out of it. I mean, we don't even know what's going to come out of it. I can tell you what my company would end up seeing out of it, but what everybody else, because everybody else manages their pipelines differently. So, it's going to be a mixed bag. We'll see. I'll be very curious on how that reporting goes over time because even now, I don't know if everybody's reporting everything that they're supposed to be reporting. 07:29 Rhett So, all pipes regulated, it's driven around leaks. Again, that also kind of surprises me. That's a sidebar. I don't want to go down because I feel like methane reduction was a, I feel like it's losing steam. It is right now. Within the current administration. But regardless, we find ourselves in this regulated space. So, help me understand briefly, what does the least regulated gas gathering line look like now? And what would the most regulated gas gathering line look like now? 07:57 Mark Well, I mean, the most regulated gas gathering pipeline would be our type A, which has been regulated in the same capacity since 2006. So basically, type A is anything operating over 20 % SMYS that is going to be impacting a class 2, 3, or 4. So high population densities make sense. It's basically what I would call transmission light. The only thing you're not doing on it is IMP. So, you're not doing integrity assessments or anything of that risk, but everything else, all your corrosion, everything, got to do it. Then probably your next highest regulated would be your type B, which is everything below 20 % SMYS that is, again, impacting class two, three or four. Again, that was done in 2006. That's been that way for quite some time. In the grand scheme of impact on industry. B’s and A’s didn’t really change much on it. What got more interesting for gas gathering operators is the intro of type C and type R. 09:11 Rhett Yeah, you had to keep D through, you had to skip D through Q. Maybe R just means reporting. 09:21 Mark I don't, I don't know. I don't know where that are actually. 09:25 Rhett Do you think it's a placeholder? Do they have like parts and code where they put holder placeholder place? There's going to be eventually D, E, F, G, H .I .J. 09:33 Mark I would not be, I would not be surprised when we start talking at that because of how they did type C. So, type C is only basically eight inch and above. Mark So. all those assets that are on performance -based plans? Type R's usually you don't do much or anything with. 10:08 Chris I mean... So, it's the opposite. Yeah, it's more like Mader less like a race car. Yes. Mark Well, Mater can drive pretty fast backwards, so, you know. Chris Dude, this is so funny because Mati's actually on cars right now, like the first movie. So it's really interesting. It's always on it at my house. 10:26 Mark I am past those days now. Thank goodness on. I loved watching it, but there's only so many times you can watch that movie before just you start nitpicking it too much. But no, type R's tend to be a lot more of your low pressure, low flow. So, stuff that's 80 PSI, 120 PSI. I mean, now you do have other ones, but usually when I think of type R, it's more of those lower pressures. Now there are more in that, which is why it's very confusing topic and why I get asked the question all the time. Like, what type of pipe is this? Is this a C or what am I supposed to even do if it's a C? 11:02 Chris Homework for us, we need to find out why they went from C to R. And that way, all are your listeners, if you ever bump into one of us, no emails or phone calls. Somebody's going to respond on the one. Yeah, if you bump into us, then you can ask him, be like, hey, did you ever find out why they went to type R? I've got to find out. Rhett So, in that context then what were the big changes for operators, we know it had big impacts. What were the hold crap impacts for operators in part 3. 11:35 Mark First, the went down to 8 inch because GPAC originally had it set for 12 like it was 12 12 12 12, then the rule came out eight so at that point we were all scrambling going well we were set up for 12 we had all the plan everything ready to go for 12 it had already been approved by GPAC they had all the language set up and then that's not what came out hard balls 11:59 Rhett Chris what do you think they're going to get sued for cost benefit no okay all right carry on that 12:05 Mark They did get sued on that one, but it failed. Oh, they did. Yeah, no, the GPAC and whatnot went out for a lawsuit on that one. It failed. Well, that's what we didn't hear about it. There you go. 12:18 Rhett So first point of contention, our first point of scrambling, was you had a whole bunch of lines that got roped in that you were not expected. Mark Yeah. I mean, from what I've seen from other operators and even ourselves, we went from like I'm like, oh, we're expecting a small subset to, crap, we just quintupled it. That subset that we were originally looking at. And we were all set to go. But there's a lot of nuances with trying to figure out because you still had, well, that was the other point of contention was it was originally three years. And they gave us a year and a half to kind of get everything lined up for compliance issues. So, you know, that was point of contention number two is, well, you added milage then you cut the time. That’s usually the opposite of what you would anticipate. They did allow us to ask for extensions depending on how many miles you have to work with. I’ve seen multiple quintupled and I’ve seen going for something like I have to figure out 10 ,000 miles of pipe if it's type C or what and these are this category to now I have 25 ,000 miles of pipe that I have to look through. That's personnel, that's time. That's a lot of energy. 13:35 Chris That was the impact that I thought too. Like for me that translated, the immediate translation was, you just mentioned, was more associated with data gathering and reporting. Yeah, right? Because a lot of times your culture, like your organizational energy is focused on operating the line, right? Moving product from A to B and operations. Now you have this huge focus in a short period of time of saying, do we know where these assets are, do we know what it is, and can we report to FMSA what they're asking? Correct. And that is a, that's a mindset shift, right? I mean, if you think about that, right? It's like the annual report already, we feel like I would say we've got a handle on annual reporting now. But now you do on an asset class that you've never done it for and they're everywhere oh yeah the infrastructure the human personnel how do you transfer information from the field into something like a GIS where you're systemizing the report now there's a new report so back to one of our favorite new phrases interpretation mechanics of the report wait did they mean this or did they mean that all of this with the time bound of i think originally was what one and a half years one and a half years so i thought that was significant that was for me was the big one 14:39 Mark yeah no it was it was a heavy lift and shift. To kinda get that mindset going. A lot of it has to do with the fact that gas gathering has been unregulated. So you dont have much in headcount besides your asset engineers that are trying to keep your plants going like your integrity engineers that are really doing a lot of the data gathering. 15:04 Chris Mindsets are different, right? Maintenance and data gathering for analysis are really different. Mark So I mean, you saw a huge shift once that came out, even with in most organizations to try to figure that out unless you had a very small mileage. So your bigger operators, it was a huge change. Smaller operators, because I've seen a few that are rid of the 400 mile range. It's like, you know, they're like, it's 400 miles. We'll, we'll get to it. It's fine. So again, it depended on operator size, too, on how big of an impact that was. So that eight inch really did play, the timeline played, but then it got even more convoluted with some of the exemptions that they threw in for type C. So type C is are after B, next most regulated. But all type C is not created equal. So if it's over 8 inch, class 1 and operating over 20 % SMYS, it's type C. But you don't have to have an established MAPE if it's less than 12 inch. If it's over 16 inch, you have to do everything that the code says. But if it's less than 16, If I don't have something within the PIR, I get exemptions out of it. So it's trying to figure out and play out what diameter I am at. Do I have something in the PIR? What additional things do I have to do? So I try to figure out what you actually have to implement is even a challenge on it. And I think one of the biggest questions that I get out, okay, it's type C is like, well, yeah, it's type C. We've coined the term like additional requirements. Like Yeah, it's an 8 –inch type C, but we got to do the additional things here because we have something within the PIR. So it gets into a balancing act there for just other people in operations because they don't know. They just hear, oh, it's type C, what do I got to do? You got to give me more details here. 16:56 Chris I'm sure there was a reason for that. What do you think it is if you had to speculate or unless you know? What do you think? 17:06 Mark I would prefer not to speculate on it. 17:13 Rhett Well, I'm curious now, so what I was hearing is that that's got to drive now, and maybe this isn't a big deal, right? So I heard, like, awareness and staffing up just to figure out what class our pipes are. Like, we have this whole thing. Now we have to create awareness. But now if you have subclasses that are depending upon think, subtypes, depending upon interactions in the PIR, now you have the potential for things to shift. Yeah. Yeah, right? So if I go build a campground over your, 17:30 Mark It's something you have to be looking at it every single year. Like once it's in, it's in. Like that's, that's a, that's an easy. But it's something you're doing like your HCA class updates. Like you're having to do that regularly just to keep up with it because as soon as the structure comes in, now I have to go do the additional requirements, which one of the biggest additional requirements and one of the pinch points was corrosion control. I mean, it's not cheap and easy to do, on a line that’s technically had it. Rhett So these lines, give me an example, is it 6 inch, 8 inch , or Mark Well its all of them. For corrosion control, well if you have something within the 8 inch on the PIR you’d have corrosion control 18:20 Rhett So you didn’t have corrosion control? You just, would you like, like, not coated, no CP pads? Mark Well, it would have coding on it, but it probably wouldn't have CP pads. Chris You could run into failure, to be clear. Yeah. So I remember a couple projects where we had. 18:31 Rhett So essentially, wait, it's like managing no threats. You just don't have, well, there is no integrity management. I got it, but you're just running the pipeline. 18:38 Mark Correct. That would have been historically how everything would have done. How it could have gone. You literally run it to the ground. Chris And then when it leaks, you find it, you replace it. You move on. that piece of pipe. The corrosion rates on some of these assets are trying to get to. I've been on a couple of projects where in two and a half years. 18:56 Rhett I just watched Ms. Producer go, what? She did like a double take on the backside when she heard that because she's heard us talking up. Yeah. So now you have to implement a corrosion plan? Yeah, corrosion control. I don't know if I'm more shocked that they were operating with nothing. I thought they would operate with something. 19:08 Mark Well, it depends on the operator so um and you know Rhett but they're not required they weren't required to operate right to operate so i could go put a pipe in the ground and as long as i was operating at some diameter some SMYS away from the public i can transmit whatever i wanted through it Chris that's how it was that's how it was yeah that's what i'm trying to get to you i saw a project at a former employer where they came to us the line was installed within two years and it was a a trunk gathering line and uh they had through wall metal loss everywhere and by design life if you think about it there's no way that should have happened and so they were trying to ask us how can we identify where we're near near failure because it was basically every couple of joints they're getting through walls through walls rolls in under two years and so the culture back then was just tell me where it is so I can cut out and replace it one joint at a time or we're going to lay a new line 19:56 Rhett yes I'm not saying thoughts that I have. Just, wow. Mark It's a different perspective. So putting in corrosion control, I mean, if it hasn't had it already, which, again, type A is going to already have it and some of the other ones. So it's not like it's unfamiliar or anything in that space. But when you start adding, like, oh, I got to go put in 10 ,000 miles of CP system, that's not an easy ask, especially in a year and a half, two years. 20:28 Rhett Oh, so this wasn't like the other gas rule, which said you have to have a plan to complete it. No. You had to have it all completed. Oh, yeah, that's a lot. Yeah, you have to have it in place. That's tough. 20:37 Mark So that, okay, let's just take the corrosion control. Okay, I can buy CP. That's fine. I can buy the beds. Installing it. Yeah. There's a limited amount of people who can install it. 20;50 Rhett Why didn't we start a corrosion bed program, man? We could have launched a company to build corrosion beds. I feel like we missed the boat here, Chris. Mark Well, that's done now. So that's the other side of the curve. So most of that's in place. But it's not just CP. You have to have internal corrosion, too. So it's a full program on it. 21:10 Chris And the internal corrosion stuff was the stuff that I saw was the nastiest. Yeah, because what you're pulling out of the ground. Rhett Weren't they monitoring that through coupons? So, like, where operators, like a lot of them, not even using coupons? Chris They had forgot where they were, and the leaks were finding them before they remember where the coupons were. Not you guys. Yeah. 21:24 Mark And for coupons, especially in the gas gathering world, it might not be in the most ideal place. It depends also what your threat is on the internal corrosion, whether it's top side, traditional bottom side, or all over the place. So depending on where that coupons are at, you might get misreadings on it. So it's something to be aware of it. Chris So basically what we're saying is it's this is a good thing. More regulation is a good thing. 21:53 Mark It is. Chris We didn't say this regulation. We said regulation is a good thing. It's progress. It's improvement. It is progress. And honestly, somewhat needed, right? I mean, if we're going to be clear, right? 22:07 Yeah. No, I, I, dont disagree at all on that. Its something some of your bigger operators were already looking into, looking at what they could start doing there before this rule came out. It was a shock to us with the scope change. Um, again, if it was the over 12 inch that was originally planned, not a huge issue, but you start adding a lot more mileage. It becomes a lot more daunting. So, um, I know a lot of operators are scrambling, uh, because I, we've been talking to the corrosion control, uh, and implementation people and they're going, we don't have enough people. Yeah. That there's just not enough manpower to do this. Um, so again, you saw a lot of, uh, CPs companies spring up to help out on that. Then theres other parts of it like damage prevention's like number one like you have to have it out there you have to have that program in place so you know when you're already doing it on almost all your lines anyway it that one to me it's not to say it's not important at all 100 % is but it was probably one of the least impactful things because we were already doing it but there there's definitely a lot of other ones in there that become a little bit more like the leak surveys, that is something that, you know, typically you would maybe walk the line every once a while. Now you're actually having to fly or do something else a little bit more, which, again, good, uh, that we're finding the emissions. We're finding the leaks. We're fixing them. Uh, but again, on the same note, it's daunting. Um, because it's just scope increase, right? Yeah. 24:10 Chris You're talking a lot more mileage no a lot of times you see regulation happened due to failure and so the type C is class one right so that's how they're kind of closed the gap was there a type is there a class one gas gathering failure that kind of sprung this up that drove the type C that we know about not that I'm aware of yeah I'm curious I think we should do some more work on that too homework part two yeah 24:34 Rhett well I tell you this is actually a place for a break because I want to come back. I actually want to talk about where you, this sounds like the beginning, Mark. I want to talk about where you think it's going to go from here, right? Or do you think it's going to stop altogether? Like, hey, is this it? Now that we've regulated gas gathering, we're done. I highly doubt that's the answer because usually things have a thrust, like a momentum to them. And I'm curious to get your perspectives on what you think the future for it looks like. So to our audience, hang on. We'll be right back as we continue our conversation with Mark Ryan. Alright welcome back to our podcast discussion on gas gathering lines. Mark as we get back into this, little be a rapid fine. Free time board games or movies? 25:25 Mark Depends on if I have company over or not company over board games just the family movies okay um Rhett That's fair apple or android Mark Oh apple i used to be an android but once once once they came out with the xr that told me they got rid of the button at the bottom i was i was a happy camper Rhett Wow that's disappointing Mark I know I know my my wife was the same way but uh she liked the button button for the apples. Rhett Okay. It's okay. You know I don't have to be friends. It's all right. Astros or Texans? Mark Neither. Do I have to pick between the two? Rhett I don't guess you do. I mean, I was going to bait you and say UofH or Iowa State, but I knew which one that one was. We know who does that. That's going to cyclones all the way. Mark Depends. Really? Basketball, Basketball, yes. Football, that might be a little bit different. Chris UofH is going to take you guys in basketball. Mark Oh, I don't doubt it. You get in the NCAA tournament. Rhett I don't remember how Mike answered these questions. These might be fun. Would you rather do with hard spots or geohazards? Mark Neither. Rhett You must choose a threat that you are stuck with. You are now the lead of. Mark I already am the lead of hard spots. So. I would say of the two which one would I rather mange I would say hardspots. Mainly because its not one thats going to be continually changing like you would with the geohazards. 27:08 Rhett Okay. I have to buy it. That was it. We're done. All right. So, Chris, take it away. Chris No, I just, what I'd come to is it's, you know, we had Andy Drake on a couple years ago, and some of the insight he gave us was, you know, when they were formulating what I'll call IMP 1 .0, it was this whole idea. We need to start somewhere. So where do you start, right? And that was kind of the birth of HCA's. And then, you know, with IMP2 .0, we now see MCAs. And the idea is it's your expanding the breadth of or reach of IM across the different asset types for transmission integrity. And this feels a little bit like that, right? When we think of this new rule or the part three of it, it's I feel like the focus, as you said, if I got this right Mark is it's type c and type r yeah and and c just brought it brought in class ones into it now correct and um and it feels a lot like the priority was on the two most significant threats right so it really was trying to hone in on what mattered right so it's like hey we have a gap in in class ones and we have a gap on the two principal threats of third party damage and corrosion. So take your medicine industry. 28:25 Mark I don't know if I would use take your medicine industry on that one. But on that same aspect, yeah, I mean, we industry knows our two biggest threats are typically going to be corrosion and third party damage. You can prevent those. Now you're getting into less normal threats out there like cracking fatigue and whatnot, It requires a lot more engineering and analysis to go through. So doing that, we've been doing transmission lines for years. It's definitely prescriptive on it. It's kind of, I mean, I hate to say more of our bread and butter, we're used to it. So bringing that in, is it a huge lift and chip mindset? Not doing it. It's just the assets we're doing it all now. I would say is the bigger thing. So, I mean, I would say on that one. It’s not something we are unaccustomed to doing. It’s not a huge issue to preform those tasks for, its just staffing up and making sure we have everything in place to do it. It does cost quite a bit of money which is, hindsight on it. But, yes, I do see them going towards broadening it out, which they already did in type A and B. I mean, that is part of the requirements for type A as well. So, and that's the thing to know, type A doesn't mean the entire line's type A, just that class two, three, four. So you can actually have a line that is type C, type A, type C. Chris Dynamically segmented. 29:55 Correct. Very, Very similar to how you would have HCA's versus non -HCAAs and MCAs. Similar aspects to that. So, again, some of those lines already had corrosion control programs on it for portions of it. So it's expanding it. Other ones had it nowhere on it. 30:13 Chris But we can imagine a lot of them didn't, though. Rhett So this is my challenge, right? I felt like in the Andy Drake episode, again, to go back to that, there was the idea that. And Keith Lavis said the same thing. Look, we started with the concept of HCA's because we couldn't apply integrity everywhere. Yeah. And we needed a starting point. And he said, you know, they made an agreement to, I think the original date was 2025 to apply integrity everywhere on the transmission line. Then it got backed up to 2035. But he was like, again, the concept of an HCA was a starting point. Yeah. And the mindset behind the regulation was this is a baseline. We're eventually going to apply it everywhere, but we're just going to start here. But I don't know that in 20 years, I feel like that's really what happened. I feel like the regulation became a minimum standard and a target. And once the target was achieved, that's kind of where it stopped, right? So for instance, you had some operators that expanded outside of HCA's. You know, maybe their response criteria outside of HCA's, they would have responded similarly in non -HCA's. But I definitely know you have a lot of operators that didn't, right? If it wasn't an HCA, they didn't respond the same way. They didn't take the same integrity protocols in non -HCA, which means that, I mean, I might say it. Maybe it wouldn't make me popular, but I don't think that fulfilled what the expectation was in the regulation. 31:42 Mark Well, I also think you're getting a secondary pushback on that one, and that is public response to everything on it too. The public's wanting us to do more. I mean, let's just be frank about it. It's pretty clear that they want us to be better. Otherwise, we wouldn't have nearly as many regulations or anything else. 32:05 Rhett The The concept of public license, right? It's our license to operate. Mark It's our license to operate on that. So I think you're starting to see a shift more with the transmission, especially on the transmission lines to go, okay, technically, if I don't have an HC or MCA, I don't have to do an integrity assessment program on it. Don't. I've been seeing a shift in industry that you're seeing more and more operators start to do that because it is their license to operate. They don't want to have a bad day on their transmission line. 32:32 Chris But a lot of it was regulatory driven. So like you said on those dynamic segments, like if you have a, uh, an MCA based assessment, if you have the data on a non-MCA, you still have to respond to it equally, right? So there is that broadening. Rhett However, it's been broadened. The recent rule definitely broadened the scope. They, they grabbed onto sections that were non-HCA for the first time. We saw, we saw that for sure. Yeah. 32:54 Mark And I don't think you've seen much of the industry push back on that one. I think a lot of the industries kind of, we've been there on that side of the fence to go, okay, yeah, that's not a problem. I mean, we've been treating non-HCA's, again, depends on the operator. It does depend on the operator. But you've seen a lot of the bigger, especially a lot of the bigger operators, like, I don't want to have a leak. So this is my license operator. I don't care if it's non-HCA. I don't want a leak. Now I might not respond to it in the same criticality like an immediate where I have five days, you know, might be something as soon as feasible because I want to get my HCA's taking care of first and then start working towards the rest. Again, depending on the feature and everything else. So again, there's a lot of nuance to it. It's definitely not a direct science. It is an art form with working through that. But I've been seeing more and more of that with the transmission space. And, you know, gathering, we started with the type A, type B working through that. Now we've brought it out to type C. You know, I, to me, it looks, it feels like it's pre-IMP right now. Because right now, you do not have to do anything integrity management right wise on any gas gathering lines period besides your initial hydro you have to build it to transmission scope for new construction but and then you have to do your type categories but integrity management is never it's all maintenance and operations right now maintenance operation at current point um do i expect that to change over the years more and likely it's going to broaden further I would not be surprised if integrity management comes in at some point yeah now what lines what types I think that's kind of to be debated as time goes on and I can also see additional scope coming in to why does it go from C to R maybe maybe there's a A few more diameters in there. Placeholders. Yeah. I hope it's not that many Rhett. Rhett Is that 15? Yeah, it's 15 in between there. So 15 different classifications. 35:10 Mark I hope not. Four is already enough. Five, we might be able to manage with. Six is starting to get a little bit excessive in there. But, I mean, we'll see how it comes. And as an operator, you know, we'll deal with it. I mean, it just gets more confusing, but that's why we have experts within each company to kind of finagle and work through all that and be able to hone that in. The hard part's articulating that to the broader audience, you know, just your ops people. They don't understand the nuances between that. They don't deal with the regulations. They just know it's type C or type R or type a like that that's all they know they don't understand all the nuance that goes into and all the additional things that we have to do there unless they're actually having to do them so 35:56 Chris what about the topic of um i mean obviously i am i am is not in the gas gathering world yet but if we think of the two approaches of prescriptive based or performance based initially what are your thoughts 36:13 Mark Well i would first say on that that you have to start somewhere which I have been seeing even just talking to ILI vendors they're doing a lot more in gathering space now they're actually industry is running integrity assessments in the gathering space now and that's opening up a whole another can of worms of things we didn't know now we're seeing so for me You have to start where, you know, you can do some significant risk reduction. I think they've already kind of gotten there someplace on that one with trying to work on your two primary threats with corrosion control and damage prevention. After that, you're talking a lot of miles that, I mean, it is 426 ,000 miles that was incorporated into regulations. 90 ,000 plus type C. Is I think roughly what the estimate is. That is a lot of miles that have never been assessed or done anything with. For a lot of operators they don’t even have integrity engineers who could do that assessment even if they wanted to. You are going to see a big shift in hiring more people, a lot more more consulting work, which might be good for you guys. But you're going to have a lot to go do, and not all assets are created equal. I mean, gas transmission is one thing, liquid transmission. Like, you have a pretty solid revenue. Gas gathering is not the same because it depends on your BTUs, what's going in there, how long, how many different pipelines it gets, goes through, you know, you could be going through hundreds of miles of gas gathering, and you're not making much, again, just depending on the line and your sell point. So trying to do prescriptive on everything could actually sink some lines, like to where I'm losing money. So you would just abandon the line at that point. So on that side really more of a performance base and risk base. Is really kind of where I would anticipate you almost need to go. Take care of the lines that are the highest risk that are high pressure, those are going to be your riskier lines on it versus, you know, something operating at 170 PSI. I mean, if that, if that tends to have an issue, it's probably going to be a leak. Do we like leaks? No. But I would rather have a leak than a rupture. Especially depending on what you're transporting. You transport high H2S. Well, okay. Maybe not the H2S scenario. I'm more, more scared of leaks on H2S than I am on ruptures 40:00 Rhett So that's interesting. I’m thinking through, IM is the direction they move eventually whether its in our lifetime or the next 5 years. So if they open the door for performance, I think that puts a tremendous burden on the gas gathering operators because performance only works if you perform. But then we got to that whole what was the driver behind the regulation. Again, I think it puts a burden because if they don't perform, then prescriptive comes, right? 39:43 Mark Yeah, and I think there's always going to be some prescriptive, like just like with transmission. I mean, look at the new noticeful rulemaking where they came to industry said what can we strip back how can we deregulate I wouldn't say deregulate but make the regulations make more sense Chris yeah should not make you put resources where they don't matter 40:15 Mark correct let's increase the effectiveness of where a resources go and a lot of that's shifting now more towards performance based or have that engineering assessment that we can do to prove that hey this is not really an issue at this current point in time, let us reassess it again in the next one. Chris You can still have a performance based assessment as long as the safety standard is where we want it to be. Which would drive your response so the analysis technique can be different. Instead of having to do this assessments vs when I do a performance assessments its looking at this data I can wait a little bit. But can always have a common safety standard, right? Is it's our safety factors will be this. Correct. And our response criteria once you understand something will be this. Your rupture pressure ratios will be this. 40:58 Mark I would expect, again, similar to like the gas transmission, like you're going to have probably a depth. You know, if you put, you'd have a critical depth where like, no, you guys need to take care of that. Like it doesn't matter if you do all the analysis. You're not working out it, you probably need to go fix that. Same thing with some of the pressure, you know, failure pressure ratios as well. I could see some prescriptive, but you really have to work on it more performance to a certain extent. And, you know, as an operator, there might be some of them, but, you know, if it comes up to where, like, I need to be looking at probably just replacing the line before I ever get to it. Because I know what's going to happen on, you know, if I run an assessment on that, that line. So, you know, there's a lot of nuance to it, which is, again, why I think performance is where it really needs to go and risk ranking. Like, if it doesn't bring me a lot of value and I have to do a ton of things on it, like, why? 42:00 Rhett It just seems odd. It seems counterintuitive to me that we would do performance based on our lowest risk lines and then we do prescriptive on our higher risk lines. It's also because of the economics. I got it. Mark I’m not saying no you could get a lot of pushback on that. I mean just adding in the new rules were looking at we got a lot of pushback from the operators that wanted more prescriptive to just get, they want that because it is an easier sell for them 42:30 Chris To get dollars. Dollars and I would say less engineering work that needs to go on in the background. Like when you get to performance base, you have to have a lot of engineering on that. You have to do a lot of it. You have to do a lot of analysis. Chris The data gathering part is going to be the most expensive part of it, right? Mark Correct. And versus I have purely prescriptive. Go do it. There's tools out there. You have your SIM, Dynamic risk, all those, where you can click a button, it's got all the codes in it, it'll spit out a list for you. Which responses are? Yeah. And you just go do it. That's like the minimum standard that they're at now. 43:09 Rhett So I'm going to wrap this up because I've enjoyed the conversation. Now that you've worked on both sides, you've worked for, I won't say which one's the dark side and which one's the light side Chris Depends on your perspective. He's worked on three sides, bro. He's been in the ditch. Rhett That's fair. I was thinking on the transmission side and the gathering side. Mark Consultant side, too. Don't forget that. The only one I haven't been on to right now is the ILI vendor. So I've gone to that dark side. 43:37 Rhett You won't get comments for Chris or eye on that. I was thinking just between gathering and transmission, which space do you prefer to play in? If you could only choose one space to play and work in the rest of your life. Somebody at your work might be listening to this. Mark I get both, I have all gas, I have transmission and gathering. Rhett Young kid comes out of college looking for a job, he’s got an opportunity for transmissions or any operator. Yeah, they have both. And then he's got an opportunity to go into a gas gathering, small, midstream operator. 44:14 Mark I would say it depends on the person and their perspectives on things. If they're very, very regimented and don't have a lot of critical thinking yet, transmission is the way to go. And that's where I would push them. I mean, it's something we talked to interns and everything else at Phillips 66 all the time on that because we have liquid transmission, gas transmission, gas gathering, though, my group's both gas. And usually with the transmission, you're a lot more regimented. It's spelled out. It's spelled out. It's very spelled out prescriptive. So it's very easy for a new hire younger engineer to get in and start picking things up. 45:03 Chris And loss of SOPs, too. You got lots of SOPs, do this, do that. Yes. 45:06 Mark Gas gathering doesn't. It's a lot of critical thinking. Rhett Drop you in the cornfield, solve this problem. Mark With guidance. Maybe not enough water. Chirs So there's a time base here. You need to hurry up. It's almost the end of the year. Mark Yeah. So it's different. So if I were to look at a new hire coming in, it's going to take them longer to develop in the gas gathering space usually. Chris But the skills sets have to be different too, because you said something earlier that we didn't focus on too much was the economics part of it, right? Like prescriptive regs could sink some pipelines. It's the same thing here. I can imagine being an integrity engineer or an engineer on the gathering side and knowing that I have an issue on multiple assets and I'm having to not just risk rank them, but also find out where the most value for the dollar is. 45:57 Mark It's something that we do every single, every single time with the gas gathering. Chris Whereas on the integrity side, true integrity side transmission, that's a little bit less of a discussion because it's a mature program, right? We know what things cost. Mark Well, and you're not doing things typically for the first time on a transmission. You've done it five times so if a surprise happens it is a legit surprise like that that wasn't there last time sure we need to go fix that versus the gathering you're going I'm opening a Pandora's box I don't know what I'm going to get here turn over that rock yes Chris I meant to grab the one next to it look what I found a that doesn't happen at P66 though no no That doesn't happen at P66. These are all metaphorical. Mark But I mean, the same thought kind of goes into it where, you know, you have to understand what you could be getting into and how much value it is to go, you know, should I just abandon the line, replace it, do something else that might be more economical than trying to fix it because I do not have the revenue stream that is transmission. So it is a different perspective. So there's a lot more critical thinking that has to happen in the gathering space. But I would look somebody four or five years down the road, would I think they would be better started if the started in gas gathering because it will suit you better as you get further up. On that same note you will delay like your first one or two three years you will be behind somebody typically in a transmission space so again it depends on your perspective and where really where you want to be 47:40 Rhett Well mark so this was great it was I really enjoyed having you on hope it's not I hope we come back around and have you again for another topic related to gathering but really appreciate your time today to our audience hopefully you enjoyed hearing a little bit about something that's honestly not native or really really close to Chris and I in many ways. Everybody go LinkedIn friend to him. We want to see his followers explode. All right. And thanks. And to our audience, we'll be back in two weeks. Appreciate you joining us on this episode. 48:05 This episode of Pipeline Things, executive produced by Sarah Etier hosted by myself and Christopher DeLeon. Special thanks to our guest, Mark Ryan, and the work well for letting us shoot here. As a friend once told me, what's the difference between a mortician and a pipeline operator. They're old. They both bury their problems. Oh.