The Texas Railroad Commission Adopts New Rule Requiring Integrity Management Plans for Natural Gas and Hazardous Liquids Pipelines:

On April 10, 2001, the Texas Railroad Commission (TRRC) issued new regulations requiring integrity management plans for all natural gas and hazardous liquids pipelines within the state. The rule includes changes to the draft rule published in the Texas Register on November 24, 2000 and will be in 16 TAC Chapter 8 entitled "Pipeline Safety Regulations." Operators with both intrastate and interstate pipelines may use an assessment plan developed for interstate facilities provided that the interstate plan meets the requirements of the new § 8.101.

The rule requires Operators to develop pipeline integrity assessment and management plans for all intrastate transmission and gathering lines subject to 49 CFR 192 or 49 CFR 195. Each Operator's plan must be completed by February 1, 2002 on a system-by-system or segment within each system basis. An Operator may select either a "risk based" or a "prescriptive plan" assessment approach. The rule requires Operators to utilize either hydrostatic testing or in-line inspection for integrity assessments or to have TRRC's prior approval before using an alternative integrity assessment method such as direct assessment. Reassessment requirements and treatment of offshore segments are also addressed in the rule. Operators must notify the TRRC when the plan is complete and then TRRC staff has 185 days to either accept the plan or determine which sections are not in compliance.

If an Operator selects the "risk based" assessment approach, 50% of the initial integrity assessments must be completed by January 1, 2006 with the balance complete by January 1, 2011. The Operator must perform a risk analysis for each segment that considers such factors as population density, prior in-line inspection results, consequences of a leak or failure, previous leak history, etc. The Operator then ranks the results of the risk analyses and performs its first integrity assessments on those segments having the greatest risk

For Operators electing the "prescriptive plan", the rule contains tables that identify by service, pipe size and location the deadlines for making initial integrity assessments. Certain specified initial assessments must be complete by January 1, 2006 with all other initial assessments finished by January 1, 2011.

RCP will conduct a 2 day workshop on DOT Pipeline Regulations on May 15 and 16th in Houston. This workshop will present an overview of all the current DOT regulations for pipeline operators, including recent regulatory initiatives such as operator qualification and pipeline integrity management. It will be followed by a half day workshop on May 17th dedicated to OPA-90 oil spill response planning for DOT pipelines. Both of these workshops are suitable for personnel who need a general introduction to DOT pipeline regulatory requirements. Additional information is available on our website HERE.

Due to a delay in mailing the registration materials for this seminar, the early registration discount is being extended to May 4th, 2001.

RCP will repeat our 2 day workshop on Pipeline Integrity Management on July 17 and 18th in Houston. This workshop presents a detailed analysis of the recent federal Pipeline Integrity Management regulation and the management programs / elements that it requires. We will also review recent state initiatives / proposed rules on pipeline integrity management. On the 18th we will discuss various methods of actually conducting a risk assessment for pipeline segments, and will work though several hands-on examples. We received very positive feedback from the Pipeline Integrity Management workshop that we conducted in March, and expect the July session to fill up rapidly. Additional information is available on our website HERE.

On April 30, 2001, the Office of Pipeline Safety proposed to conform the pipeline facility drug and alcohol testing regulations with corresponding DOT regulations (Procedures for Transportation Workplace Drug and Alcohol Testing Programs). They also proposed miscellaneous changes to the pipeline facility drug and alcohol testing regulations to make them easier to apply and understand. The proposals are intended to ensure the pipeline facility drug and alcohol testing regulations are clear and consistent with the DOT regulations. The proposed rule can be downloaded from RCP's website HERE. FOR FURTHER INFORMATION CONTACT: L. M. Furrow by phone at 202-366-4559, by fax at 202-366-4566, by mail at U.S. Department of Transportation, 400 Seventh Street, SW., Washington, DC, 20590, or by e-mail at buck.furrow@rspa.dot.gov.

States are becoming more aware of pipeline safety issues and are moving to assert their authority on safety issues. Some examples of this growing trend are identified below;

* State of Washington. The State Legislature passed and sent to the Governor for his signature on April 19, 2001 legislation funding a new pipeline safety program. The legislation requires interstate pipelines to pay for an inspection and monitoring program for pipelines transporting hazardous liquids. The program will fund four inspectors who will have responsibilities for both new and existing interstate systems.

* State of Texas.(See article above) The Texas Railroad Commission issued on April 10, 2001 regulations requiring integrity management plans for intrastate gathering and transmission lines subject to 49 CFR 192 or 49 CFR 195. The new rule can be found in 16 TAC chapter 8. Initial plans must be complete by February 1, 2002 and maintained in an on-going manner thereafter.

* State of Florida. The Florida Public Service Commission is preparing safety rules for intrastate natural gas pipelines. These rules will likely contain provisions for integrity management, leak surveys, odorization of gas, installation of pipeline valves, corrosion control and other related issues. The timing for issuing the new rules has not been determined.

The API 2001 Operator Qualification Conference II is scheduled to take place at the Sheraton Baton Rouge on the 30th and 31st of May 2001. This conference is of particular importance not just because it affords opportunities to those who could not attend the February conference, but also because regulatory deadlines are just ahead. Pipeline operators must have a written qualification plan by April 27, 2001. And by October 2002, no person may perform a covered task on a pipeline unless the company has evidence that the person is qualified to perform that task. Consequently this conference is indeed a watershed for the pipeline industry. Workshop and seminar topics will include the covered tasks in API Pub 1161 and additional sub-tasks not included in Pub 1161. Participants will discuss the audited OQ plans with the auditors who reviewed the plans, as well as Learn what it takes for contractors and owners to work together to succeed with operator qualification. For more information on the conference please log on to http://www.api.org/training/Conferences/OQconference/.

Editor's Note: I look forward to meeting you at the conference!

Pending Audits?