Understanding PHMSA's Latest Leak Detection Rule

What You Need to Know About PHMSA’s Upcoming Gas Pipeline Leak Detection Rule

Want to know what’s going on with PHMSA’s upcoming Gas Pipeline Leak Detection rule? You’re not alone! We’ve had loads of questions from pipeline operators on what they’re going to need to do to comply and how we can help. We wrote this article to help you make informed decisions. We’ll explain several important provisions we might see in the final rule and illustrate how our technology satisfies these requirements. 

Most of the regulatory information comes from the initial rule proposal or recommendations to PHMSA from Gas Pipeline Advisory Committee (GPAC) meetings. While we don’t have a crystal ball to see exactly how things will play out, and PHMSA reminds us that GPAC recommendations are nonbinding, we’ve been keeping our ears to the ground, so we’ll share what we’ve learned so far. 

When Will the Rule Go into Effect?

The word on the street is that the rule will go into effect early to mid-2025. Following the rule effective date, operators will need to develop a written Advanced Leak Detection Program (ALDP). GPAC recommended an 18-month window for initial ALDP development.   As part of the program, operators will have to complete a documented analysis that considers the state of the art in leak detection equipment and practices and use this procedure to design a program that fits the needs of their infrastructure. After the initial program development, the analysis and program updates would need to be repeated at regular intervals (PHMSA proposed an annual cadence).  Bridger is happy to share our expertise in leak detection technologies. 

Updated Technology Performance Standards and Frequencies

There was extensive feedback to PHMSA that they needed to update technology performance requirements to match the capabilities of aerial remote sensing technologies due to their effectiveness for gas pipeline leak detection. PHMSA listened closely to this feedback, and it was intensively discussed during the GPAC meeting. 

At GPAC, the following emission rate detection sensitivity standards for aerial leak detection technology were recommended to PHMSA: for transmission and gathering pipelines, a detection sensitivity of 10 kg/hr (~540 scfh) with a 90% probability of detection (POD). For pipelines in the distribution segment, a 0.5 kg/hr, (~27 scfh) detection sensitivity with 90% POD. Bridger’s Gas Mapping LiDAR™ technology demonstrably achieves these detection sensitivities. 

In addition to specifying leak detection technologies, an operator’s ALDP will need to specify screening frequencies for pipeline segments. In the final rule, there will be fewer exemptions for leak detection and some increased screening frequencies compared to older PHMSA regulations. For example, GPAC recommended that Type C gathering pipelines are screened yearly for large-diameter pipelines and once every five years for smaller-diameter pipelines. In the past, smaller diameter Type C gathering pipelines (that are away from buildings intended for human occupancy) didn’t have leak detection requirements. As you’re probably aware, Type C gathering pipeline is a relatively new class of pipeline that was designated by PHMSA in order to regulate gathering pipelines in rural areas when they are of significant size or pressure (you can learn more about this in our previous blog linked here.) As a rule of thumb, pipelines located within high-consequence areas and higher class locations will require more frequent leakage surveys than annual. Distribution pipelines, on the other hand, will have lower leak survey frequencies. 

PHMSA clearly intends to get prescriptive on leak detection performance requirements in this rulemaking. Another one of their objectives is to collect more information on the leaks that are detected. They proposed to update annual reporting to include counts and aggregate emissions volume estimates for leaks by grade and other emissions by source category.  Emissions estimates are intended to involve direct measurement. This is an area where Gas Mapping LiDAR technology shines because of our best-in-class emission rate quantification, providing highly accurate aggregate emissions estimates.

How Can Bridger Photonics Help Operators with These New Requirements? 

Over here at Bridger, we’re queued up to help you with your compliance needs. Our airplane and helicopter-mounted sensors can efficiently scan hundreds or even thousands of miles of transmission, gathering, and distribution pipelines. Since our lasers scan throughout methane plumes, we precisely identify where emissions are coming from and rule out false positives due to emissions from nearby oil and gas infrastructure, wetlands, and feedlots. This keeps your operations focused on fixing leaks instead of chasing ghosts. 

Bridger’s Gas Mapping LiDAR can operate under a wide variety of environmental conditions and meet your compliance windows. Our sensors don’t depend on clear skies and direct sunlight to perform correctly because we use lasers for methane detection. The underlying technology performance also means we can still reliably detect methane under a wide range of wind speeds. 

PHMSA requires operators to detail the technology calibration, performance validation, and deployment protocols in their ALDP.  At Bridger, we’ll help take care of this. We’re getting our technology approved within an EPA Alternative Test Method which will cover these aspects of technology use and you can incorporate our test method into your ALDP. As a bonus, you will be able to complete EPA methane rule scans at your compressor stations while you’re deploying Gas Mapping LiDAR for pipeline scans. Learn more about PHMSA regulations here.