PHMSA Issues Advisory Bulletin on New Requirement to Update O&M Plans

By Erin Kurilla posted 5 days ago

  
On June 10, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a new Advisory Bulletin (ADB-2021-01) titled “Statutory Mandate to Update Inspection and Maintenance plans to Address Eliminating Hazardous Leaks and Minimizing Releases of Natural Gas from Pipeline Facilities.” This is the anticipated advisory to assist operators in meeting the self-executing mandate, Section 114, from the Protecting Our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020. Operators have until December 27, 2021 to develop a plan to meet the mandate.

Section 114 modified expectations for the Inspection & Maintenance plans for all pipeline operators. Inspection & Maintenance Plans are often translated to Operations & Maintenance (O&M) plans. Prior to the passing of the PIPES Act of 2020, O&M plans must be:

(A) relevant available pipeline safety information;
(B) the appropriateness of the plan for the particular kind of pipeline transportation or facility;
(C) the reasonableness of the plan; and
(D) the extent to which the plan will contribute to public safety and the protection of the environment.

Operators must modify their O&M plans to meet the following updated criteria:

(A) relevant available pipeline safety information;
(B) the appropriateness of the plan for the particular kind of pipeline transportation or facility;
(C) the reasonableness of the plan; 
(D) the extent to which the plan will contribute to –
     (i) public safety
     (ii) eliminating hazardous leaks and minimizing releases of natural gas from pipeline facilities; and
     (iii) the protection of the environment; and
(E) the extent to which the plan addresses 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.

The PHMSA Advisory Bulletin attempts to educate operators on how to revise their O&M plans to meet these new expectations. PHMSA states that O&M plans must now be detailed to address the elimination of hazardous leaks and minimize releases of natural gas from pipeline facilities. This includes minimizing unintentional fugitive emissions and intentional, vented emissions from pipeline facilities. Examples of fugitive emissions include leaks from pipelines, flanges, valves, meter sets, and other equipment. A vented emission may be any release of natural gas from the atmosphere due to equipment design or O&M procedures such as from relief valves, blowdowns, etc.

PHMSA and state authorities will inspect all operators’ revised O&M plans during the 2022 calendar year. PHMSA staff is currently working on developing short audit protocols that can be used during these inspections. Regulators will be looking for incremental changes operators have made to their O&M, procedures, and DIMP plans consistent with the mandate that go beyond existing regulatory requirements. Examples include accelerated leak-prone pipe replacement programs, increased leak surveys, and scheduled repair of Grade 3 leaks. APGA will be working closely with other industry trade associations to provide recommendations to PHMSA on practical actions operators can take to reduce emissions on their systems. These recommendations will be reviewed by the Operations & Safety Committee prior to being shared with PHMSA.

Read the Federal Register Notice here.

For question on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at ekurilla@apga.org.

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