Congress, by passing the PIPES Act 2020, has required operators of hazardous liquid, liquified natural gas (LNG), and natural gas pipelines to “update” their inspection and maintenance plans to address the elimination of hazardous leaks and minimize releases of natural gas from their systems. This “self-executing” provision of the law must be completed by December 31, 2021. The updates must address intentional venting during normal operations along with “leaks” on the system. An operator will need to specify how they will quantify the amount of natural gas that is being released currently, and indicate what steps, measures, remediation, replacement, or repair will be done to reduce or eliminate the release of natural gas. Additionally, operators will be required to provide documentation demonstrating the effectiveness of the procedure or process. Leak classification criteria should also be reviewed to determine if there are measures that can be instituted to further expedite leak repair and replacement programs already in place.
Intentional venting typically refers to that process where natural gas is released into the atmosphere during normal operations, such as blowdowns or relief valve operation. However, the law goes on to indicate requirements for 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.
Design refers to a pipeline system designed to leak. Odd statement unless you consider there are multiple devices in a natural gas system that are designed to “leak” during normal operation. Simple examples are field telemetry devices powered by the natural gas pressure in the pipeline or the internal combustion driver on a transmission pipeline compressor unit. Both of these release natural gas into the atmosphere by design during operation. Operators should look at alternative types of telemetry or field devices that “vent” natural gas. Recapture systems on compressor drivers that reduce or eliminate the release of natural gas from the exhaust of the drivers should be considered.
As stated in the Advisory Bulletin – 2021-01, issued by PHMSA, June 10, 2021; this mandate is applicable to hazardous liquid, liquified natural gas, and natural gas pipeline operations as required by 192.605, 193.2017 and 195.402. All three regulated operations need to define processes and procedures within their normal operations and maintenance procedures that will ultimately reduce or eliminate leaks or releases of natural gas to the environment. This does apply to operators of hazardous liquid pipelines as well. Of course, the language that speaks directly to reducing or eliminating natural gas releases is specific to LNG and Natural Gas operators.
The law also clearly requires PHMSA or the designated State authority to inspect operators revised operations and maintenance plans within 2 years of publication of the law. The law states that: Not later than 2 years after the date of enactment of this subparagraph, and not less frequently than once every 5 years thereafter, the Secretary or relevant State authority with a certification in effect under section 60105 shall review each plan described in this subsection. This timeline indicates that PHMSA and the State authority have until the end of 2022 to fully inspect operators plans. They then have five years to repeat the effort. As an operator of hazardous liquid pipelines, LNG facilities, or natural gas pipelines, you must have updated your Operations and Maintenance programs by December 31, 2021 and be prepared to have those plans reviewed by PHMSA or a State authority.