PHMSA has issued a new Advisory Bulletin (ADB 2021-01) reminding operators of the statutory mandate from the PIPES Act of 2020, which 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 expects that operators will comply with the inspection and maintenance plan revisions required in the PIPES Act of 2020 by revising their O&M plans to address the elimination of hazardous leaks and minimize releases of natural gas from pipeline facilities. The plans must also address the replacement or remediation of pipelines that are known to leak due to their material (including cast iron, unprotected steel, wrought iron, and historic plastics with known issues), design, or past O&M history.
The ADB also reminds operators of the mandate that PHMSA and certified state agencies are required to inspect operators’ revised O&M plans in calendar year 2022. During these inspections, PHMSA, or the relevant state agency, is required to evaluate whether the plans adequately address items listed in section 114 of the PIPES Act of 2020:
- O&M plans must be detailed to address the elimination of hazardous leaks and minimization of releases of natural gas from the operators’ pipeline facilities; meaning pipeline operators must update their plans to minimize, among other things, fugitive emissions and vented emissions from pipeline facilities. PHMSA and state inspections, therefore, will evaluate the steps taken to prevent and mitigate both unintentional, fugitive emissions as well as intentional, vented emissions. Fugitive emissions include any unintentional leaks from equipment such as pipelines, flanges, valves, meter sets, or other equipment. Vented emissions include any release of natural gas to the atmosphere due to equipment design or operations and maintenance procedures. Common sources of vented emissions include pneumatic device bleeds, blowdowns, incomplete combustion, or overpressure protection venting (e.g., relief valves).
- O&M plans must address the replacement or remediation of pipelines that are known to leak based on the material (including cast iron, unprotected steel, wrought iron, and historic plastics with known issues), design, or past operating and maintenance history of the pipeline. PHMSA and state inspections will include an evaluation of how the material present in the pipeline system, design of the system, as well as the past O&M history of the system, contribute to the leaks that occur on the system. PHMSA and states will evaluate whether the plans adequately address reducing leaks on operators’ pipeline systems due to the aforementioned factors.
- Operators must carry out a current, written O&M plan to address public safety and the protection of the environment. In addition to the new statutory requirement that PHMSA and state inspections consider the extent to which the plans will contribute to the elimination of hazardous leaks and minimizing releases of natural gas from pipeline facilities, PHMSA’s inspections will continue to include an evaluation of the extent to which the plans contribute to both public safety and the protection of the environment.
For a copy of this Advisory Bulletin or to learn how TaskOp is now being developed to assist pipeline operators track, calculate and report methane emissions, contact Jessica Foley.