PHMSA Notice: Notice of Proposed Rule Making Leak Detection and Repair
On Friday the DOT announced a PIPES Act proposal to modernize decades-old pipeline leak detection rules, investment in infrastructure, and improve safety. Included in this announcement was a PHMSA Notice of Proposed Rulemaking (NPRM) titled Gas Pipeline Leak Detection and Repair. The NPRM provides changes to Parts 191, 192, and 193. This NPRM has not yet been issued by the Federal Register but is available in PHMSA's Announcement as well as at this link.
Elemental has summarized some of the highlights of the NPRM, though the final rule language may change as comments are received and addressed by PHMSA. Comments on this NPRM must be sent to PHMSA within 60 days of its appearance on the Federal Register.
Part 191 Changes
Minor adjustment to "Incident" definition
Adds definition for “Large Volume Gas Release”
Adds provisions for a new release report for Large Volume Gas Releases on PHMSA Form F7100.5
Adds “Large Volume Gas Release” under Safety-Related Condition reports
Adds NPMS reporting requirements for Type A, B, and C gathering lines
Part 192 Changes
Adds definitions for "Confined Space", "Gas Associated Substructure", "Leak or Hazardous Leak", "LEL", "Substructure", "Tunnel", and "Wall-to-Wall Paved Area"
For Type B Lines
Adds O&M, emergency response, repair investigation/grade/documentation, patrols, and pressure relief device configuration requirements
Adds provisions for conducting leakage surveys within an advanced leak detection program
For Type C lines
Adds O&M, emergency response, repair investigation/grade/documentation, patrols, and pressure relief device configuration requirements
Adds provisions for conducting leakage surveys within an advanced leak detection program (ALDP)
For UNGS
Adds that O&M manuals must include procedures for eliminating leaks and minimizing releases of gas
Adds public safety as a consideration for blowdowns at compressor stations, exhaust gas from pressure relief valves, transmission line valves, service line conduit, service line valves, purging of pipelines, abandonment/deactivation of facilities, and prevention of accidental ignition
Adds new design and engineering analysis requirements for new/replaced/relocated/changed pressure relief and limiting devices to minimize unnecessary release of gas
Adds requirement that leaks must be repaired before pressure increases are made for uprating, and removes provision for not repairing some leaks before proceeding
Adds requirement for creating O&M procedures regarding eliminating leaks and minimizing releases of gas from pipelines as well as remediating or replacing pipelines known to leak based on their material, design, or past operating and maintenance history
Defines "Failure" under 192.617
Adds leak repair requirements under 192.760
Excludes certain patrolling/leakage survey/grading and repair and advanced leak detection programs requirements if the pipeline or compressor station is 1) subject to certain methane emission and monitoring requirements under 49 CFR Part 60 or certain EPA requirements, 2) the records are maintained for the life of the facility, and 3) the facility is within the first block valve entering or exiting the compressor station covered by the emergency shutdown system
Synchronizes all patrolling under 192.705 to be 12 times each calendar year, not to exceed (NTE) 45 days for all areas
Increases requirements around leakage surveys under 192.706 including that surveys must be conducted according to ALDP requirements, excepting certain circumstances where human or animal senses may be used
Pipelines outside of HCAs must be surveyed once per year, NTE 15 months
Pipeline inside HCAs must be surveyed twice per year NTE 7.5 month at Class 1, 2, and 3 locations and four times per year NTE 4.5 months at Class 4 locations
Non-odorized pipelines must be surveyed as follows twice per year NTE 7.5 months at Class 3 locations and four times per year NTE 4.5 months at Class 4 locations
Leakage surveys must be performed for valves, flanges, and certain other facilities twice per year, NTE 7.5 months for Class 1, 2, and 3 locations and four times per year NTE 4.5 months for Class 4 locations
Adjusts language regarding leakage surveys frequencies and requirements under 192.723 for distribution including:
Business districts annually, NTE 15 months, consisting of atmospheric tests at each gas, electric, telephone, sewer, water, or other system manhole; crack in the pavement and sidewalks; and any other location that provides an opportunity for finding gas leaks
Non-business districts once every three years, NTE 39 months
Regular leakage surveys annually, NTE 15 months, for certain cathodically unprotected distribution lines and lines known to leak based on their material design or operating history, and gas distribution systems protected by an anode system in the area of deficient readings until that area is repaired
Operators must investigate known leaks including a leakage survey for gas migration after environmental changes like freezing ground, heavy rain, flooding or other events that could cause the migration of gas to the outside wall of a building
Leakage surveys must also be performed after extreme weather events and land movement within 72 hours of the cessation of the event
Adds a new section, 192.760, for leak grading and repair requiring operators to have procedures for grading and repairing leaks. This section is applicable to all leaks on all portions of a gas line including but not limited to line pipe, valves, flanges, meters, regulators, tie-ins, launchers, and receivers. Leaks must be prioritized, investigated immediately and continuously until a determination is made
Leaks will be divided into three categories, Grade 1, Grade 2, or Grade 3. Each category has parameters for what constitutes this leak grade as well as repair or action timeframes
This section also has provisions for post-repair inspection, upgrading and downgrading leak grades, extension of repair, and recordkeeping
Requirements are added for an Advanced Leak Detection Program (ALDP) under 192.763. The ALDP must include a list of leak detection equipment used by the operator with a minimum sensitivity of 5 ppm. This equipment must be selected based on a documented analysis considering certain factors depending on the type of equipment. Types listed include handheld, mobile/aerial/satellite mounted, optical/infrared/laser-based, stationer sensors/pressure monitoring, or other methods.
Operators must have procedures for performing the surveys using selected technology, pinpointing and investigating leaks, validating equipment meets the requirements of the section, and maintaining and calibrating equipment
The ALDP is subject to continuous improvement with requirements to evaluate annually, NTE 15 months
Adds requirements for qualification of leakage survey, investigation, grading, and repair personnel
Adds requirements for minimizing emissions from gas transmission pipeline blowdowns through a series of suggested methods
Adds requirement to develop O&M procedures for pressure relief device maintenance and adjustment of configuration
Part 193 Changes
Adds eliminating leaks and minimizing releases as an O&M procedure requirement for LNG
Adds a new section regarding minimizing emissions from blowdowns and boiloff through a series of suggested methods
Adds leakage surveys for LNG facilities four times a year, NTE 4.5 months, with parameters
Elemental monitors PHMSA notices and updates and will continue to track this NPRM through the rulemaking process. If your company would like assistance interpreting and implementing these new requirements, contact us at at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com. Follow us for more updates!