The Railroad Commission of Texas (TRRC) has approved adoption of amendments to intrastate pipeline safety regulations that will have significant impacts to both gas and liquid pipeline facilities in Texas. The proposed amendments were published on October 10th (Proposed 16 TAC Chapter 8), comments were submitted (Comments), and the final rule was posted on January 15th (Final Rules). The final rules were published in the Texas Register on January 30th and will become effective on February 4, 2009. A summary of the changes is provided below. To discuss these or get more information regarding the potential impact these may have on your pipeline facilities, please contact Jessica Roger.

• The final rule incorporates production facilities and associated pipelines into the definition of Transportation of Gas, beginning at the first point of measurement through the beginning of gathering as defined by 49 CFR 192.8. However, there are no provisions in the final rule that specify compliance deadlines for these previously exempt production and pipeline facilities. It is also unclear whether the same criteria will be used for classifying production pipelines as Type A or Type B regulated, similar to how gathering line regulated status is determined. The proposed rule included language that helped clarify these issues; however, the final rule is silent. None of the changes that were proposed in Chapter 8.1 General Applicability and Standards appear to be included in the final rule.
• Changes were made to Chapter 8.5 Definitions for Master Meter System, Pressure Test, and Transportation of Gas. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.
• The final rule did not exempt gathering lines from the TRRC integrity management regulations as was proposed in October 2008. It appears that gas and liquid gathering pipelines are still subject to Chapter 8.101 Pipeline Integrity Assessment and Management Plans for Natural Gas and Hazardous Liquids pipelines.
• Changes were made to Chapter 8.115 New Construction Commencement Report. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.
• A minor change was made by relocating the Penalty Guidelines for Pipeline Safety Violations to Chapter 8.135. The previous location (Chapter 8.245 applied only to natural gas pipelines).
• Changes were made to Chapter 8.203 Supplemental Regulations to clarify expectations for enhanced corrosion monitoring for unprotected gas pipelines. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.
• Changes were made to Chapter 8.205 Written Procedure for Handling Natural Gas Leak Complaints that require supervisory review of leak complaints be completed and documented by 10:00 a.m. each day for calls received the previous day. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.
• Changes were made to Chapter 8.210 Reports and Chapter 8.301 Required Records and Reporting. Reporting triggers for gas pipeline releases were brought in line with DOT requirements (191.3). Telephone reports of both gas and hazardous liquid incidents must now include on site point-of-contact information and other significant facts are involved. Gas pipeline incident telephone reports must now include the estimated damage and lost gas costs. The most significant change was the addition of leak reporting requirements for gas distribution and regulated plastic gas gathering and transmission pipelines. The TRRC will require semi-annual reports for all leaks (except non-hazardous, easily repaired above ground leaks), all repairs made within previous reporting period, and all remaining unrepaired leaks, including leak grade. The DOT forms and reporting deadlines used for annual reporting will be used instead of the PS-45 form for intrastate liquid pipeline annual reporting. All safety-related condition reports for hazardous liquid pipelines must now be submitted to the TRRC in accordance with Part 195 requirements.
• Changes were made to Chapter 8.215 Odorization of Gas that requires gas pipelines to use only commercially available equipment and malodorants after February 4, 2009. Existing shop-made equipment may remain in place, but cannot be moved to new locations. A new criterion has been established for detection of malodorants. Revised inspection and test interval criteria clarify the TRRC expectations that these occur no more than 15 months from the previous inspection and test.
• Plastic pipe failure reporting found in Chapter 8.225 has been removed from the final rule. However, the new section under Chapter 8.210 Reports requires failures of regulated plastic gas pipelines to be included with semi-annual leak report requirements.
• Changes were made to Chapter 8.230 School Piping Testing that clarifies the TRRC expectations for applicable facilities to be tested. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.
• Changes were made to Chapter 8.235 Natural Gas Pipelines Public Education and Liaison and Chapter 8.310 Hazardous Liquids and Carbon Dioxide Pipelines Public Education and Liaison that clarifies the TRRC expectations that liaison activities occur no more than 15 months from the previous effort. These chapters also outline a 2-year interval for TRRC notification of pipeline facilities located within 1000 feet of a public school. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.
• Changes were made to Chapter 8.305 Corrosion Control Requirements that are primarily clarification and elimination of duplicative DOT regulatory language. All of the changes that were in the proposed rule appear to have been incorporated into the final rule.

Leak Management Tracking System

RCP has developed a leak management system that tracks all leaks through their life span and will allow for the reports required by the TRRC to be easily generated and uploaded into the TRRC Electronic Document Interchange process. It is a web-based application that can be customized so that field personnel can interface through laptops or hand-held devices. Because it is web-based, there are no IT issues to struggle through to get started. Simple to use, easy to access, and can be customized with GIS integration tools, etc. For more information, contact Jessica Roger.