Underground Infrastructure - July 2023 - 11

* Incorporate explicit reference to environmental
harm among the " hazards "
addressed in certain sections of the
pipeline safety regulations.
* Meet other new requirements.
PHMSA proposes an eff ective date
for this rulemaking of six months following
publication of a fi nal rule in the
Federal Register.
Leaks
Leak detection equipment must have a
minimum sensitivity of fi ve parts per million
(ppm) or less. Operators would select
their leak detection equipment based
on a documented analysis that considers
the gas transported, the size, confi guration,
operating parameters, and operating
environment of the system. An operator
may seek PHMSA review of alternative
leak detection technology.
Repair requirements would be based on
how dangerous a leak was - from Grade 1,
the most serious, to Grade 3. Grade 1 leaks
present an urgent or emergency situation,
requiring the operator to take " immediate
and continuous " action to eliminate the
hazards to people or the environment.
NPRM classifi es the following as a
Bore_Spacer-Ad_UC_2020.pdf 1 2/24/2020 10:40:27 AM
Grade 1 leak: " Any reading of 80 percent
lower explosive limit (LEL) or higher in a
substructure from which gas would likely
migrate to the outside wall of a building;
any leak that can be seen, heard or felt; and
any leak reportable as an incident under
Part 191 of the pipeline safety regulations. "
PHMSA estimates a total of 11 new
requirements would result in reducing
unintentional methane emissions approximately
72 percent from regulated gathering
pipelines, 17 percent from transmission
pipelines, and 44 to 62 percent from
distribution pipelines. Also, PHMSA estimates
total avoided blowdown emissions,
under the proposed rule, correspond to
approximately 43 percent of baseline
blowdown emissions. PHMSA further
estimates that the proposed rule would
result in monetized net benefi ts between
$341 to $1,440 million per year.
According to Susan Olenchuk, a
partner at Van Ness Feldman, " Whether
PHMSA has accurately estimated the
costs and benefi ts of the proposed rule will
certainly be a signifi cant issue that industry
will raise in their comments. Also, the
elevation of environmental protection to
be on par with safety will likely be an issue.
" In that regard, PHMSA has recently
encountered criticism from certain members
of Congress for transforming the
Pipeline Safety Act into an environmental
statute, instead of a safety statute. "
A spokeswoman for the Interstate
Natural Gas Association of America said
" As this was mandated in the PIPES Act
of 2020 we anticipated, and appreciate,
this rulemaking. We cannot comment on
the specifi cs of this proposed rule until
we have had more time to review it, and
we look forward to working with PHMSA
to ensure that the mandate can be
implemented appropriately to ensure the
safe and effi cient delivery of natural gas
through our infrastructure. " UI
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UndergroundInfrastructure.com | JULY 2023 11
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Underground Infrastructure - July 2023

Table of Contents for the Digital Edition of Underground Infrastructure - July 2023

Underground Infrastructure - July 2023 - 1
Underground Infrastructure - July 2023 - 2
Underground Infrastructure - July 2023 - 3
Underground Infrastructure - July 2023 - 4
Underground Infrastructure - July 2023 - 5
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