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Mandatory Revisions to Gas Pipeline O&M Manuals by December 27, 2021

As a reminder, there are mandatory revisions to gas pipeline O&M manuals due by December 27, 2021. The PIPES Act of 2020 (Section 113) contains self-executing provisions requiring pipeline facility operators to update their inspection and maintenance plans to address the elimination of hazardous leaks and minimization of releases of natural gas (including, and not limited to, intentional venting during normal operations) from their systems before December 27, 2021.

PHMSA released an Advisory Bulletin (ADB-2021-01) on June 10, 2021 reminding Gas Pipeline Operators of this requirement. Within the bulletin, PHMSA stated they expect operators to comply with the inspection and maintenance plan revisions required in the PIPES Act of 2020 by revising their operations and maintenance (O&M) plans to address the elimination of hazardous leaks and minimize releases of natural gas from pipeline facilities. The plans will also need to be revised to address replacement or remediation of pipelines that are known to leak due to their material of construction (including cast iron, unprotected steel, wrought iron, and historic plastics with known issues).

The revised O&M plans must include procedures for identifying, locating, and categorizing all leaks that are hazardous to human safety or the environment or those that have the potential to become explosive or otherwise hazardous to human safety. In addition, the updated plans need to include the development of criteria for repairs along with the timeframe for completing repairs.

RCP is assisting our clients, who are Really Cool People, with preparation of procedures to meet these new requirements. If you would like more information about the details of this Advisory Bulletin ADB-2021-01, or would like assistance in developing the mandatory O&M plan update, contact Jessica Foley.