PHMSA Informational Meeting on Upcoming Leak Detection Inspections

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Troutman Pepper

On January 27, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced a public informational meeting on February 17, 2022 regarding PHMSA’s plan for forthcoming audits of updated inspection and maintenance plans to eliminate and minimize leaks pursuant to Section 114 of the Protecting Our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020. According to the notice, the purpose of the meeting is to review the requirements of Section 114, which required pipeline operators to update their inspection and maintenance plans by December 27, 2021, to (1) eliminate hazardous leaks, (2) minimize releases of natural gas, and (3) address the replacement or remediation of pipelines that are known to leak due to their material, design, or past operating and maintenance history.

To ensure compliance with Section 114, the PIPES Act of 2020 requires PHMSA and certified states to conduct inspections in 2022, and PHMSA plans to discuss its approach to these inspections during the informational meeting. The PIPES Act further requires the Comptroller General to perform a study to evaluate PHMSA and state partners’ review of those plans and provide recommendations for how to further minimize methane releases. PHMSA will then report to Congress on the study and recommendations in the report.

Although the deadline for updating inspection and maintenance plans passed at the end of last year, this informational meeting will provide more insight into PHMSA’s interpretation of the self-executing provision of Section 114 and what operators can expect during upcoming inspections. The webinar will address the following topics:

  • Key elements of Section 114;
  • Significant sources of natural gas (primarily methane) emissions from pipelines;
  • Discussion on which types of pipeline facilities must comply with each portion of Section 114;
  • PHMSA and state inspections, including reviews of a pipeline operator’s programs and procedures to reduce methane emissions;
  • Inspection topics related to methane reduction and leak-prone pipes;
  • General review of how operators’ programs and procedures will be inspected; and
  • Timelines for actions required by Section 114.

Members of the public can register to attend the virtual meeting here

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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