AGA Summary of 

Existing State and Federal Leak Survey Requirements 

June 10, 2010 

Federal and State Leak Survey Regulations: Natural gas distribution operators are 

currently required to adhere to both federal and state leak reporting requirements. 

Performance based regulations drafted by the Department of Transportation (DOT) do 

not prescribe the level of detail in the proposed Subpart W, but operators are already 

completing leak surveys and reporting leaks identified in a manner that addresses the 

intent of the proposed rule. PHMSA works in concert with the state regulators to ensure 

leaks are identified and reported on a regular and, when needed, expeditious manner. 

PHMSA posts summary leak information that is collected by all the states for any 

member of the public to review: 

http://primis.phmsa.dot.gov/comm/states.htm?nocache=2058. 

AGA encourages EPA to review the state regulatory information that is publically 

available to ensure the final reporting rule does not duplicate, and where possible aligns 

with, regulatory requirements already in place. For example, if EPA finds that further 

granularity is needed to perform leak surveys on components at M&R and city gate 

stations for use in applying leaker emission factors to those components, then it would 

help to reduce costs and burdens if this component survey could be performed at the 

same time as the leak surveys performed to comply with existing state and federal leak 

survey requirements. Under 49 C.F.R. §192.723, DOT PHMSA requires LDCs to 

conduct periodic leak surveys. Section 192.723(b) provides that 

 “The type and scope of the leakage control program must be determined by 

the nature of the operations and the local conditions, but it must meet the 

following minimum requirements:

(1) A leakage survey with leak detector equipment must be conducted in 

business districts, including tests of the atmosphere in gas, electric, 

telephone, sewer, and water system manholes, at cracks in pavement and 

sidewalks, and at other locations providing an opportunity for finding gas 

leaks, at intervals not exceeding 15 months, but at least once each calendar 

year.

(2) A leakage survey with leak detector equipment must be conducted 

outside business districts as frequently as necessary, but at least once 

every 5 calendar years... However, for cathodically unprotected distribution 

lines subject to §192.465(e) on which electrical surveys for corrosion are 

impractical, a leakage survey must be conducted at least once every 3 

calendar years...” 

Annual DOT Report: Leak survey results must be reported to DOT PHMSA annually 

on Form 49 CFR191 OMB No. 2137-0522. A copy of the form is available at the DOT 

PHMSA web link provided above. 
ANSI-Accredited Industry Standards for Leak Surveys – GPTC Guide: 

A consensus industry standards organization has developed detailed guidance that 

LDCs follow to ensure compliance with the federal DOT PHMSA leak survey 

requirements. This industry standard guidance is available for purchase through AGA’s 

web site. AGA serves as the secretariat to the Accredited Standards Committee (ASC) 

Z380, Gas Piping Technology Committee (GPTC). The GPTC develops and publishes 

ANSI Z380.1, Guide for Gas Transmission and Distribution Piping Systems. Information 

is available online: http://www.aga.org/Committees/gotocommitteepages/gaspiping/ . 

The committee meets three times per year and has a list of approximately 75 open 

“transactions” (projects) to revise various provisions in the Guide. The committee 

publishes three addenda to the Guide every year which contain updates. The Guide is 

published as a new edition every three years. Copies of the cover page, table of 

contents and sample pages regarding leak surveys are attached. 

Five Year Rolling Average for Facilities in Non-Business Districts: To comply with 

192.723(b)(2), LDCs conduct leak surveys each year of 20 percent of the non-business 

district pipe and equipment, including components at M&R stations and city gates. If 

EPA decides to impose a more specific leak survey requirement under proposed 40 

C.F.R. §98.233(q) for the eight components identified in proposed 40 C.F.R. 

§98.232(i)(1), AGA asks that the agency align the survey frequency of components in 

non-business districts with the current practice of leak surveying 20% of the pipe and 

M&R and city gates components in non-business districts each year, using a 5-year 

rolling average for purposes of the leaker emission factor calculation. This should be an 

option at least for LDCs operating in a state that does not require more frequent surveys 

than the federal rule requires for non-business districts. 

More Stringent State Leak Survey Requirements: It should be noted that every state 

reserves the right to require leak monitoring and reporting requirements beyond what is 

specified by DOT. For example, effective February 4, 2009, the Railroad Commission 

of Texas required all natural gas distribution pipeline operators to submit leak reports 

every six months. Texas Administrative Code §8.210(e) requires all natural gas 

distribution pipeline operators to report leaks in accordance with the following 

specifications: 

 (e) Leak Reporting. For purposes of this subsection, the term "leak" includes all 

underground leaks, all hazardous above ground leaks, and all non-hazardous 

above ground leaks that cannot be eliminated by lubrication, adjustment, or 

tightening. Each operator of a gas distribution system, of a regulated plastic gas 

gathering line, or of a plastic gas transmission line shall submit to the Division a 

list of all leaks repaired on its pipeline facilities. Each such operator shall list all 

leaks identified on all pipeline facilities. Each such operator shall also include the 

number of unrepaired leaks remaining on the operator's systems by leak grade. 

Each such operator shall submit leak reports using the Commission's online 

reporting system, Form PS-95, by July 15 and January 15 of each calendar year, 

in accordance with the PS-95 Semi-Annual Leak Report Electronic Filing 
Requirements, set out in the Figure in this subsection. The report submitted on 

July 15 shall include information from the previous January 1 through the 

previous June 30. The report submitted on January 15 shall include information 

from the previous July 1 through the previous December 31. The report includes: 

 (1) Leak location; 

 (2) Facility type; 

 (3) Leak classification; 

 (4) Pipe size; 

 (5) Pipe type; 

 (6) Leak cause; and 

 (7) Leak repair method. 

Additional State Rule Examples: AGA plans to provide more examples of state leak 

survey regulation requirements in our written comments to be filed on June 11, 2010 in 

Docket EPA-HQ-OAR-2009-0923 on EPA’s Mandatory Reporting of Greenhouse 

Gases: Petroleum and Natural Gas Systems; Proposed Rule. Web links to several of 

these state regulations were also provided to EPA in previous email submissions in this 

docket. 

Web Links to Texas Rules:

Regulations for operators in Texas under the Texas Administrative Code are 

available on the web:

http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p

_tloc=&p_ploc=&pg=1&p_tac=&ti=16&pt=1&ch=8&rl=210. 

Distribution Annual Reporting Form (presumably to be updated to a 6-month 

format soon): 

http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/GasDistrAnnualF

orm_122005_Final_7100_1-1.pdf

Distribution Incident Reporting Form: 

http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Gas__Distr%20Inciden

t%20Form%20-%20PHMSA%20F%207100-1%20(01-2010).pdf