The Texas Railroad Commission (TRRC) has proposed several revisions to 16 TAC Chapter 8 – Pipeline Safety Regulations to address new risk management\ initiatives for the Commission’s pipeline safety evaluation program and to remove outdated or duplicative rule requirements. The amendments include new language to address onshore pipelines and gathering and production facilities. In Subchapter A, §8.1 (a) (1), new language concerning applicability of these regulations has been added that states:
The rules in the chapter… apply to:
(B) onshore pipeline facilities, including production lines and flow lines, beginning at the first point of measurement and ending as defined by 49 CFR Part 192 as the beginning of an onshore gathering line;
This appears to be intended to apply TRRC pipeline safety regulations to virtually all production and gathering pipelines downstream of the first point of measurement, and would be a potentially significant expansion of TRRC’s jurisdiction.
The other proposed revisions are relatively minor in comparison. TRRC proposes amendments in §8.1(b) to update the minimum safety standards and to adopt by reference the DOT’s pipeline safety standards found in 49 CFR Parts 191, 192, 193, 195, and 199 as of August 16, 2007. The federal safety rule amendments that will be captured include:
- requirements for direct assessment
- definition and requirements for onshore gathering lines
- updates to incorporated standards
- approval of a new breath tube alcohol screening device
- requirements for gas transmission pipelines to use design and construction features to reduce the risk of internal corrosion
- allowance for an 8 month window to the period for reassessing hazardous liquid pipelines; modifications for notification requirements for operators of hazardous liquid and natural gas pipelines, and allowance for alternatives in calculating pressure reduction when making immediate repairs on hazardous liquid pipelines.
TRRC proposes to repeal §8.245, relating to Penalty Guidelines for Pipeline Safety Violations in order to propose the same rule under new §8.135 with the same title – moving the penalty guidelines for pipeline safety violations from Subchapter C, which applies to requirements for natural gas pipelines only, to Subchapter B, so that the guidelines will apply to all pipelines.
Some recordkeeping requirements are proposed to be removed from the rules, and to reduce the number of incident reports telephonically reported to TRRC. However, there will be an increased cost of compliance for natural gas operators for the proposal to require the semi-annual reporting of identified and repaired leaks in their pipeline system.
Under §8.210(b)(1), TRRC proposes to add that each operator must file an annual report for its intrastate systems located in Texas in the same manner as required by 49 CFR 195 using forms supplied by the DOT. In addition, a new subsection (e) on Leak Reporting is proposed requiring natural gas operators to submit a report (semiannually) regarding repaired and unrepaired leaks on their pipeline system, including a description of the leak and the method of repair. A second report will also be required that will list the number of unrepaired leaks on the pipeline system. Reports will be submitted online into TRRC’s Pipeline Safety Integrity system on June 30 and December 31 of each calendar year.
Other proposed amendments include:
- clarifying wording in §8.205 to state that supervisory review of leak complaints must be completed and documented by 10:00 a.m. each day for calls received by midnight on the previous day.
- requiring that gas odorization must be verified by the supplier using commercially available odorization equipment.
- requiring that commercially available malodorants must be used, and clarification that malodorant tests must be done at intervals not exceeding 15 months, but at least once each calendar year.
- clarifiying that school facility pipe testing must include all gas piping from the outlet of the purchase meter to each inlet valve of each appliance.
- deleting from §8.305 the requirement for atmospheric corrosion control and changing the requirements for cathodic protection test stations.
Comments on the proposal are due by 5:00 p.m. on November 26 and may be submitted online at www.rrc.state.tx.us/rules/commentform.html; or by email to email@example.com.
For a complete copy of TRRC’s proposed revisions, contact Jessica Roger.