Methane Leak Monitoring Requirements in the New PHMSA Rule

Back in the olden days of 2020, rural natural gas gathering pipelines were like the wild west… no federal regulations. The pressure in these rural lines was typically low, and they presented limited safety hazards because they were not near populated areas. With the increased scrutiny of methane emissions’ impact on the environment and a goal of increasing safety throughout gas gathering and transmission, all of that is changing. The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a new rule on November 15, 2021, that will regulate an estimated 400,000 miles of existing gathering lines. The rule includes two new pipeline classifications along with new regulations for leak detection and other safety and reporting requirements. Below, we’ll provide a quick summary of the newly regulated pipeline categories and leak detection requirements established in the new rule, which is slated to take effect May 16, 2022.

1.    All Gathering Pipelines are now Regulated by PHMSA Alongside Transmission Pipelines.

The new PHMSA rule revises the Federal Pipeline Safety Regulations to “improve the safety of onshore gas gathering lines.” Prior to this new rule, much of the gathering line networks in the US were not federally regulated, meaning they had no reporting or maintenance requirements under DOT requirements. PHMSA created two new pipeline classifications, Type C and Type R, to cover all previously unregulated gathering lines. To figure out exactly which gathering lines fall under the new regulations, you first need to understand PHMSA’s Class location system, and pipe type designations. 

Class Locations Define the Population Density Near Transmission & Gathering Lines.

PHMSA uses four Classes to categorize how close natural gas lines are to people. Class 1 applies to pipe in a rural location, while Class 4 indicates a densely populated location. With safety as a primary concern, pipes in Class 4 locations have more regulations than pipes in Class 1 locations. Before this rule, gathering pipes in Class 1 locations did not fall under the PHMSA rules at all. It’s the pipes in Class 1 locations – those in the wild west of rural unregulated pipes – that are the motivation for the new rule. 

New Pipeline Classifications Type C & Type R Introduced

Prior to this new rule, PHMSA only defined two gathering line types: Type A and Type B. Type A gathering lines operate at higher pressures and follow the safety regulations of transmission lines. Type B lines operate at lower pressures and have fewer safety requirements (§ 192.9). Neither Type A nor Type B designation applied to Class 1 locations, so up until now any pipe in a rural location wasn’t covered under PHMSA. To wrangle and round up these untamed gathering lines, PHMSA added a new Type C pipeline classification. Type C lines share the same pressure definitions as Type A lines but share similar safety requirements to Type B lines. For those gathering lines that are still in the boonies and operate at low pressure, a new Type R designation was also added. Basically, Type R is the catch-all for everything not covered by Types A, B, and the new Type C. Type R, or ‘‘reporting-regulated gathering” lines, only require incident and annual reports – no leakage or safety regulations.

2.    Annual Monitoring with “Leak Detection Equipment” is Now Required.

Just like transmission lines, “Leakage surveys” have been required for Type A and B gathering pipelines for years, and the number of required surveys per year depends on the location. For Type C lines, leak monitoring is required only if the pipe is over 16 inches in diameter OR near a building. 

These applicable Type C pipes require once-per-year leakage surveys. If your Type C pipe is less than 16 inches AND not located near a building intended for human occupancy per § 192.9(f), leakage surveys are not required (though other rules apply). See the Frequency Requirement Summary Table to learn more.

Specific leak detection equipment and requirements aren’t specified, but the possibility of using handheld equipment, fixed leak detectors, and vehicle-mounted equipment such as “aerial sensor platforms” is mentioned. Check out § 192.706 for more detail on leakage survey requirements. It’s also important to note that the leakage survey requirements do not distinguish between gathering lines and transmission lines.

 3. New Regulations Start in May of 2022

The effective date for this rule is May 16, 2022, so it’s time to get going on leakage survey plans! The first annual report to PHMSA is due March 15, 2023, for the 2022 year. So, for Type C gathering lines, it’s time to head ‘em up, move ‘em on toward new compliance standards.