The Railroad Commission of Texas (TRRC) has approved adoption of amendments to pipeline safety regulations that will have significant impacts to gas production and gathering pipeline facilities in Texas. This is the second final rule published by the Texas Railroad Commission in the last month. The proposed amendments were published on October 10th (Proposed 16 TAC Chapter 8), comments were submitted (Comments), and the final rule was posted on February 10th (Final Rules). The final rules were published in the Texas Register on February 27th and became effective on March 2, 2009. A summary of the changes is provided below.
- Chapter 8.1 General Applicability has been amended to incorporate gas production pipelines downstream of the first point of measurement, treating these essentially the same manner as a gas gathering pipeline. In a previous final rulemaking, production pipelines were incorporated into the definition of Transportation of Gas, but the specific compliance requirements and deadlines where not discussed. With this new rulemaking, the Texas Railroad Commission clearly specifies which gas production pipelines are regulated and the dates in which these newly regulated pipelines must be in full compliance. The same criteria used for regulated gas gathering (i.e. Type A and Type B) will be applied to gas production pipelines. Therefore, any onshore gas production pipeline located in a Class 1 area will remain exempt from pipeline safety regulations. Gas Production pipelines located in Class 2, 3, or 4 areas will be regulated and must comply with the same requirements as Type A or Type B gas gathering pipelines. The dates for these newly regulated pipeline facilities to be compliant are as follows: Date pipeline placed into service: any new, replaced, relocated, or otherwise changed March 1, 2010: Establish Maximum Allowable Operating Pressure per 49 CFR 192.619 September 1, 2010: Establish and implement Damage Prevention program per 49 CFR 192.614 March 1, 2011: Install and maintain line markers per 49 CFR 192.707 March 1, 2011: Establish and implement Public Education and liaison per 49 CFR 192.616 March 1, 2012: Establish and maintain cathodic protection requirements per 49 CFR 192 March 1, 2011: for Type A lines, comply with all other provisions applicable to Type A gas gathering lines per 49 CFR 192.8(c)
- Chapter 8.101 Pipeline Integrity Assessment and Management Plans for Natural Gas and Hazardous Liquids Pipelines has been amended. The final rule eliminates gas gathering pipelines from the assessment schedule for inline inspection, pressure testing and subsequent remediation requirements. Gas transmission pipelines are still subject to this schedule found under 16 TAC Chapter 8.101(b)(2).
To discuss these or get more information regarding the potential impact these may have on your pipeline facilities, please contact Jessica Roger.
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.