16 TAC Chapter 8 – Pipeline Safety Regulations
The Texas Railroad Commission (TRRC) adopted new §8.206, ‘Risk-Based Leak Survey Program’ effective September 1, 2008, for operators of gas distribution pipeline systems. The adopted rules require Texas gas distribution companies to establish a risk-based schedule of increased leak inspections; standardize leak grading and repair time frames; and repair or remove and replace certain compression couplings due to leaks or serviceability. No later than March 1, 2009, each operator shall have completed and submitted to TRRC either a prescriptive or a risk-based program for leak surveys for its pipeline systems that complies with the requirements of this section.
When establishing a risk-based schedule, pipeline operators are required to:
- create a risk model on which to base its leak survey program to identify those systems or segments within systems that pose the greatest hazard and thus will be inspected for leaks more frequently
- re-evaluate and update its leak survey inspection program to address any changes that may be identified through the monitoring of the pipeline system in accordance with the requirements imposed by 49 CFR 192.613 (relating to Continuing Surveillance)
The determination of leak survey frequency is determined by classifying each pipeline segment based on its degree of hazard associated with each risk factor; i.e., pipe location; age of the pipe and nature of the piping system; corrosion history; environmental factors, etc. Surveys should be conducted more frequently in those areas with the greatest potential where leakage could be expected to create a hazard. Operators must establish their own risk ranking for pipeline segments to determine the frequency of leakage surveys. The inspection interval may range from quarterly to every 5 years.
Operators electing to use a prescriptive leak survey program must conduct annual leak surveys for all systems within a business district; every 5 years for non-business district polyethylene segments; every 3 years for all other non-business district cathodically protected steel segments; and every 2 years for all other non-business district segments.
Each operator must ensure that its leak detection equipment is properly calibrated and that leak grading is made only by those individuals who possess training, experience, and knowledge in the field of leak classification and investigation, including extensive association with actual leakage work. Operators must comply with the requirements of new §8.207 for all leaks reported on or after September 1, 2008. Leaks identified prior to September 1, 2008 require repairs by the dates in the table below:
Type Identified Prior to: Repair Date Grade 2 September 1, 2008 March 1, 2009 Grade 3 September 1, 2008 September 1, 2011
- Grade 1 leaks are defined as an existing or probable hazard to persons or property and requires the operator to take immediate action to eliminate the hazard and make repairs.
- Grade 2 leaks are non-hazardous at the time of detection and can be scheduled for repair on a normal routine basis with periodic reinspection at least once every 30 days until the leak is repaired or cleared. Grade 2 leaks vary greatly in degree of potential hazard and may require a scheduled repair within the next 5 working days and others within 30 days. This new section outlines additional criteria that require repairs made within 6 months of detection of any leak.
- Grade 3 leaks are non-hazardous at the time of detection and can be reasonably expected to remain non-hazardous. Operators must repair a Grade 3 leak within 36 months of detection.
- There is a concise reference table for leak grading and leak repair deadlines in §8.207(g).
Section 8.208 pertains to the mandatory removal and replacement program of leaks identified on compression couplings that join both steel and plastic pipe, with an effective dated of September 1, 2008.
- For leaks identified on any underground compression coupling used to mechanically join steel pipe, operators must either replace the leaking compression coupling or repair it using a sleeve welded over the compression coupling.
- Operators are required to repair or replace any compression coupling used to mechanically join steel pipe that is exposed during operation and maintenance activities unless the operator can determine the coupling was installed after 1980.
- For leaks identified on any underground compression coupling used to mechanically join plastic pipe, operators must remove and/or replace the leaking compression coupling.
- For any other compression coupling used to join plastic pipe that is exposed during operation and maintenance activities (2-inches or less in diameter) operators must replace or remove coupling unless the operator can determine that the coupling is designated as an ASTM D2513 Category 1 type fitting. For plastic pipe greater than 2-inches in diameter, operators must replace or removed coupling unless the operator can determine that the coupling is designated as an ASTM D2513 Category 1 or Category 3 type fitting.
For more information, or a copy of the new rule, contact Jessica Roger.
Has the Gas Gathering definition affected your pipelines?
RCP can conduct a detailed analysis of your gas pipelines to determine end points of production and gathering based upon the recently finalized definition of gas gathering pipelines. The analysis will also determine whether your gathering pipelines are regulated and whether they are classified as Type A or B regulated gas gathering. For more information, click here to contact Jessica Roger.