The key parts of the rules:
OMHST has required coal mine operators to conduct public record searches or otherwise determine whether there are any gas pipelines or wells within an area to be mined within the next 12 months. They are then required to serve by certified mail, a notice to the gas operator of a map showing the Designated Mining Area (DMA). The gas operator then has 6 months to complete the mapping and/or marking of the pipelines in the DMA, and the coal operator has obligations to map the locations on a certified mine map; conduct specific, additional marking when mining activity is to take place in proximity to the pipelines; to inspect and replace any pipeline markers damaged or destroyed; and conduct specific training of coal mine employees regarding the location of pipelines and safety issues when operating nearby.
In the OOG regulations (Section 16.8), which are to complement the OMHST rules, upon receipt of a notice of the DMA from a coal operator, the gas pipeline operator is required to map or mark the pipelines in the DMA. The standard for mapping and marking depends on whether it is a Pressure Bearing, or Non-Pressure Bearing Natural Gas Pipeline. Note: any buried pipeline is considered a Pressure Bearing pipeline. Only pipelines that are on the surface and operated at or below 40 psi are considered Non-Pressure Bearing. The only distinction is that for Non-Pressure Bearing pipelines, the operator can provide a topo map or drawing of the approximate location of the pipeline to satisfy the regulation, whereas for a buried or over 40 psi surface line, the operator must supply a survey map, a GPS, or mark the pipeline with pipeline markers space at no greater than 600 foot intervals.
The specific method of mapping and marking is noted in the regulations in Section 16.8. After mapping or marking, the gas operator is required to file a notice of compliance with the OOG, with a copy to the coal mine operator.
In addition, Section 16.8.f. requires that while mining activities are ongoing in the DMA, that when entering or leaving the DMA, the gas operator is required to attempt to check in and out with the mine operator. This is a good faith effort requirement, and does not apply in emergency situations. You will also note these regs do not apply to interstate/DOT jurisdictional lines.
OMHST Emergency Pipeline Marking Rules - Click Here
DEP OOG Emergency Pipeline Marking Rules - Click Here
But more can be done, should be done, and needs to be done if we have any expectation of building the critical mass we need to ensure the intent and structure of the Safe Drinking Water Act remains intact through the remainder of the session, and beyond.