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Regulatory Update

PHMSA Releases Proposed Rulemaking for Pipeline Safety and Gas Pipeline Leak Detection and Repair

Alan Mann | June 15, 2023

PHMSA’s 52 proposed regulatory amendments would reduce methane emissions from new and existing gas pipelines

The US Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing regulatory amendments pertaining to 49 Code of Federal Regulations (CFR) Parts 191, 192, and 193 regarding Pipeline Safety: Gas Pipeline Leak Detection and Repair that would reduce methane emissions from new and existing gas transmission pipelines, distribution pipelines, and regulated facilities (Types A, B, C, and offshore gas gathering pipelines, underground gas storage facilities and LNG gas facilities).

Written comments on this NPRM must be submitted by August 16, 2023. PHMSA proposes an effective date for this rulemaking of six months following publication of a final rule in the Final Register.

Purpose of Regulatory Action

This series of proposed regulatory amendments comes in response to a bipartisan congressional mandate in the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020 (PIPES Act), as well as in support of the Biden-Harris Administration’s U.S. Methane Emissions Reduction Action Plan.

PHMSA proposes to revise the regulatory language in this provision to incorporate within its regulations the section 114 of the PIPES Act of 2020 self-executing mandate that operators update their procedures to provide for the elimination of leaks and minimize release of gas from pipeline facilities. Section 192.12(c) obliges operators of underground natural gas storage facilities to have and follow written procedures for operations, maintenance, and emergency response activities.

PHMSA proposes a total of 52 new and revised updates to the regulations.

Proposed Changes

PHMSA is proposing amendments to Type A, B, C and offshore gas gathering pipelines, underground gas storage facilities and LNG gas facilities to include reducing methane emissions, strengthening leakage survey and patrolling requirements in CFR 192.705 and 192.706.

Performance Standards for Advanced Leak Detection Programs

PHMSA is proposing new performance standards for advanced leak detection programs (ALDP). Section 113 of the PIPES Act of 2020 requires PHMSA to issue performance standards for operator leak detection and repair programs reflecting the capabilities of commercially available, advanced leak detection technologies and practices. To satisfy this mandate, PHMSA proposes to introduce a new requirement that operators establish written ALDPs performance standards for both the sensitivity of leak detection equipment and for the effectiveness of those ALDPs.

This new requirement would provide benefits to both public safety and the environment by ensuring that pipeline operators have programs in place to promptly detect and repair leaks of all gas pipelines subject to part 192.

New Leak Grading and Repair Criteria

PHMSA is proposing a new requirement for leak grading and repair criteria with mandatory repair timelines. As stated in Section 192.760 (Leaking grading and repair), this addresses grading and repairing leaks on gas distribution, transmission, offshore gathering and Types A, B, and C gathering pipelines. The leak grading concept and many of the leak grading criteria are similar to those in the Gas Piping Technology Committee (GPTC) Guide, which has been adopted in some operator procedures and State pipeline safety requirements. This will include Grade 1, Grade 2, and Grade 3 leaks.

Pressure Relief Design Requirements

PHMSA is proposing the following Pressure relief device design, configuration, and maintenance requirements:

  • Section 192.199 – Revise to add: New, replaced, relocated, or changed Type B and C gathering lines would be subject to the pressure relief device design and configuration requirements.
  • Section 192.773 (Pressure relief device maintenance and adjustment of configuration) PHMSA proposes this new regulation to require operators of all gas distribution, transmission, offshore gathering, and Types A, B, and C gathering pipelines to have written operating and maintenance procedures for assessment of the proper function of pressure relief devices.

Clarified Investigative Failure Procedures

PHMSA is proposing the clarified requirements for investigating failures. For the purposes of the existing requirement to investigate failures, PHMSA proposes to define the term “failure” for the purposes of Section 192.617 to mean “when any portion of a pipeline becomes inoperable, is incapable of safely performing its intended function, or has become unreliable or unsafe for continued use.” PHMSA considers any leaking gas pipeline as having failed to perform its intended function. This proposed regulatory amendment would apply to gas distribution, gas transmission, offshore gas gathering, and Type A regulated onshore gas gathering pipelines.

Blowdown Mitigations

PHMSA is proposing new requirements, in Sections 193.2525, for mitigation of emissions from blowdowns (minimizing emissions from blowdowns and boiloff). These new requirements would require operators of part 193-regulated LNG facilities to mitigate methane emissions from non-emergency, vented releases such as blowdowns and tank boiloff.

TRC’s Recommendation

TRC recommends becoming familiar with the Department of Transportation PHMSA Gas Pipeline Leak Detection and Repair NPRM – May 2023, Docket Number PHMSA-2021-0039, RIN 2137-AF51, located at

Alan Mann

Mr. Mann has spent 22 years as a pipeline safety regulator and consultant with personnel and program management experience. He is an experienced and accomplished leader, and his background includes leading and participating on teams conducting Standard Comprehensive State pipeline safety evaluations, and Specialized Evaluations of Pipeline Integrity Programs, Drug and Alcohol Program Compliance, Damage Prevention, Public Awareness, New Construction, Accident Investigation and Operator Qualification programs. He has excellent communication and people skills and is highly regarded for his ability to determine pipeline jurisdictional status and to develop Compliance Responses to Regulatory Findings, Operations & Maintenance Plans, Public Awareness Programs, Integrity Management Plans, Damage Prevention Plans, and Emergency Response Plans. He is a SME of the Code of Federal Regulations (CFR), particularly 49 CFR Parts 191, 192, 193, 195 and 199. Mr. Mann is a US Army veteran of 6 years serving with distinction and has earned a BS from West Texas A&M University as Summa Cum Laude in General Studies.

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