In This Issue

ANPRM: Pipeline Safety: Repair Criteria for Hazardous Liquid and Gas Transmission Pipelines

[Docket No. PHMSA-2025-0019]

PHMSA published an advance notice of proposed rulemaking (ANPRM) on May 21, 2025, to gather stakeholder feedback on potential amendments to Parts 192 and 195 including repair timelines, remediation criteria, integrity management rules, and re-assessment intervals to ensure regulations maintain pace with modern technology and best practices without imposing unnecessary burdens. Additionally, PHMSA is requesting feedback pertaining to the authorization of a risk‑based approach for determining inspection intervals on in‑service breakout tanks.

The ANPRM noted that hazardous liquids and carbon dioxide repair requirements have not been substantially updated for decades, and they may not sufficiently provide for the use of advanced technology and current pipeline industry best practices. PHMSA has requested comments pertaining to:

  • Anomaly categorization and remediation timelines for could affect (HCA) and non-could affect pipelines
  • Alternatives to existing anomaly repair criteria and remediation timelines
  • Anomaly evaluation methods in the absence of known material properties
  • Adopting predicted failure pressure-based criteria for anomalies
  • Repair criteria timelines for metal loss anomalies along a longitudinal seam weld for could affect (HCA) and non-could affect pipelines
  • Dent evaluations and Engineering Critical Assessments
  • Dents with metal loss or other interacting threats

With respect to gas transmission pipelines, PHMSA stated that gas transmission repair criteria were last revised in 2022 following the San Bruno incident; some of those changes are under litigation and PHMSA has not conducted a holistic review since. PHMSA requested comments pertaining to:

  • Dents and Engineering Critical Assessments
  • Engineering Critical Assessment methodologies using current industry standards
  • Cost and benefits associated with Engineering Critical Assessments
  • Dents with metal loss or other interacting threats
  • Re-assessment for anomalies that were evaluated using Engineering Critical Assessments

For hazardous liquid breakout tanks, PHMSA has requested feedback pertaining to how tanks should be inspected and repaired, and inspection frequencies.  PHMSA asks if incorporating a risk-based inspection interval would be appropriate for breakout tanks.

Public comments are due by July 21, 2025, and PHMSA plans to hold a public meeting to supplement or to clarify the materials received.

For a copy of this ANPRM, please message Jessica Foley.