PHMSA Webinar on Emissions Reduction Expectations and Inspections
PHMSA hosted a webinar on February 17, 2022, to discuss procedural emission reduction expectations and upcoming inspections for all oil and gas operators with assets subject to transportation requirements based on Pipes Safety Act 2020, Section 114. This was an unusual regulatory approach for PHMSA. The rule was written as a “Self-Executing Mandate”, meaning the requirements are automatically enacted and enforceable without code language changes. PHMSA issued an Advisory Bulletin, Statutory Mandate to Update Inspection and Maintenance Plans to Address Eliminating Hazardous Leaks and Minimizing Releases of Natural Gas from Pipeline Facilities, on this topic in June 2021 reiterating operators requirements to update Operations and Maintenance (O&M) Manuals to include emissions reductions strategies by the end of December 2021. Additionally, PHMSA discussed these requirements and announced inspections beginning in 2022 at the Gas and Liquid Pipeline Advisory Committee Meeting held in October 2021.
Who is Included?
Any oil and gas operator with assets subject to regulation by PHMSA and associated State Agencies:
Natural Gas Pipeline Operators
Hazardous Liquid Pipeline Operators
Underground Natural Gas Storage Operators
Liquified Natural Gas Operators
Regulated Gathering Line Operators
Non-natural Gas Operators (Propane)
What is Included?
Operators must incorporate emissions reductions processes into O&M Programs and Procedures for two key areas:
Emissions Reductions (venting, blowdowns, fugitive emissions from compressor stations and meters, etc.)
Include details such as data collection and analysis, trending, detection methods, training for personnel
Include what actions will be taken and what thresholds trigger those actions
Ensure smaller sources are included
Some specific ideas and examples are:
Alternative repair considerations (i.e., reducing cutouts)
Classifying leaks and what the time frames are for those classifications
Alternatives to pressure relief testing (i.e., testing in place versus offline, using alternatives to natural gas for testing, etc.)
Identifying and addressing specific processes such as flaring (for transportation facilities only) - monitor for complete combustion, gas detection alarms, etc.
Design processes (i.e., reduce vibrations, relief valves, minimize releases from slug catchers, etc.)
Leak-Prone Pipe
Applies to all operators (hazardous liquid operators must consider support lines for equipment)
Include documented process to review pipe data for any systemic issues
Process should include criteria to define leak-prone for all types of pipe (i.e., material, age, location, etc.)
Additional consideration should be given to cast iron, bare-steel, and plastics known to have problems
Include repair and replacement procedures with metrics on how emissions may be reduced during this process
When are Due Dates?
Procedural changes were due to be made by the end of December 2021
Agencies will begin programmatic inspections in February 2022 and will complete inspections on all operators by the end of 2022
Implementation inspections will begin in 2023
PHMSA will post Illustrative Inspection Questions in February 2022 but these questions are subject to changes and additions
Where and How will Inspections be Completed?
Most inspections will be performed separately, but they may be bundled with other inspections
Separate inspections will most likely be performed virtually
There are approximately thirty (30) inspection questions but not all questions may be applicable to all operators and assets
Inspections may include more than one OPID if the assets lend themselves to similar questioning
Inspections will be performed by PHMSA and State Agencies
If operators have already been inspected and are contacted by another Agency, please communicate the previous inspection and the Agency will decide how to proceed
If you have questions or would like support in meeting these new requirements, please contact Elemental Compliance at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com.
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