PHMSA Seeks Stakeholder Input on Pipeline Safety Repairs and Breakout Tank Inspections
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued an Advance Notice of Proposed Rulemaking (ANPRM), scheduled to be officially published on May 21, 2025in the Federal Register (Docket No. PHMSA-2025-0019), to solicit stakeholder feedback on improving the cost-effectiveness of repair requirements for gas transmission, hazardous liquid, and carbon dioxide pipelines under 49 CFR Parts 191, 192, and 195. Additionally, PHMSA is exploring risk-based inspection intervals for in-service breakout tanks. This initiative aims to modernize regulations to reflect technological advancements and reduce compliance burdens while prioritizing safety.
Summary of Objectives
PHMSA seeks to address three primary areas:
Updating repair criteria and remediation timelines, particularly for hazardous liquid and carbon dioxide pipelines (§195.401 and §195.452), which have seen minimal changes in over two decades, to better incorporate modern technologies and practices.
Evaluating the potential for risk-based inspection intervals for in-service breakout tanks (§195.432), moving away from the current default annual inspection requirement.
Responding to stakeholder recommendations, National Transportation Safety Board (NTSB) guidance, and executive orders (E.O. 14192, 14154, and 14156) that advocate for streamlined regulations to support energy infrastructure and innovation.
Background and Context
PHMSA’s regulations for gas transmission (Part 192) and hazardous liquid pipelines (Part 195) combine prescriptive repair requirements with risk-based integrity management (IM) rules for high-consequence areas (HCAs). These regulations have contributed to improved safety trends since 2005, reducing incident frequency and severity. However, some requirements, particularly for hazardous liquid pipelines, have not been updated in decades and may not reflect advancements in pipeline safety technology. Recent rulemakings, such as the 2022 gas transmission rule following the 2010 San Bruno incident, and subsequent litigation (e.g., INGAA v. PHMSA, 2024), have prompted PHMSA to reassess repair criteria. For breakout tanks, industry feedback suggests that the annual inspection mandate may impose unnecessary costs, potentially addressable through risk-based approaches.
Key Questions for Stakeholders
PHMSA is requesting detailed input on several topics, including:
Whether current repair criteria, remediation timelines, and IM requirements balance safety and compliance costs effectively, and if specific amendments could enhance cost-effectiveness without compromising safety.
The extent to which regulations accommodate innovative technologies for anomaly detection, evaluation, and remediation, and whether specific provisions inhibit their adoption.
The appropriateness of incorporating prescriptive elements within risk-based IM regulations (§192.712, §195.452) and potential amendments to optimize flexibility and safety.
The clarity and practicality of defining the “discovery” of anomalies for initiating repair timelines (§192.714, §192.933, §195.401, §195.452).
The potential for codifying PHMSA interpretations to reduce compliance burdens and their applicability to different pipeline categories.
Variations in pipeline characteristics (e.g., size, capacity) that may justify tailored repair and IM requirements.
Types, costs, and prevalence of temporary and permanent repair methods, including adherence to industry standards like ASME B31.4.
The impact of regulations on small businesses and alternative approaches to minimize disproportionate effects on these entities.
The necessity and potential redundancy of remediation-related reporting requirements under Parts 191 and 195.
Alignment of anomaly remediation prioritization with PHMSA’s statutory mandate to prioritize public safety (49 U.S.C. 108(b), 60102(a)(1)).
For hazardous liquid and carbon dioxide pipelines (Part 195): The application of IM criteria to non-HCA segments, the feasibility of predicted failure pressure-based criteria, and the suitability of engineering critical assessments (ECAs) for anomalies like dents or metal loss.
For gas transmission pipelines (Part 192): The appropriateness of ECA requirements for dents (§192.712(c)), incorporation of industry standards like API RP 1183, and the suitability of re-assessment intervals.
For breakout tanks: The feasibility of adopting risk-based inspection intervals aligned with standards like API Std 653.
PHMSA requests data on incremental costs, benefits, and methodologies, including per-unit and programmatic impacts, to inform a forthcoming Notice of Proposed Rulemaking (NPRM).
Submission Details
Comments are due by July 20, 2025, though late submissions may be considered if practicable. Stakeholders can submit comments via:
Online at
https://www.regulations.gov
(Docket No. PHMSA-2025-0019).
Mail or hand delivery to DOT Docket Management System, 1200 New Jersey Avenue SE, Washington, D.C. 20590-0001.
Fax to 202-493-2251.
Confidential Business Information (CBI) submissions must be clearly labeled and accompanied by a redacted copy, per 49 CFR 190.343. For further details, contact Sayler Palabrica at sayler.palabrica@dot.gov or (202) 744-0825.
Significance and Next Steps
This ANPRM reflects PHMSA’s commitment to updating pipeline safety regulations to support innovation and align with energy policy objectives. It provides a critical opportunity for pipeline operators, technology providers, and other stakeholders to influence future regulations by submitting data-driven feedback on repair practices, inspection methods, and compliance challenges. PHMSA plans to hold a public meeting to further discuss these topics.
Call to Action
Stakeholders are encouraged to review the ANPRM and submit detailed comments by July 20, 2025, to shape regulations that balance safety and practicality. Access the full ANPRM at https://federalregister.gov/d/2025-09078.