Host: Evon, you're good to go ahead and get started.
-: Okay, sounds good.
Hello, good afternoon.
My name is Evon Boothe,
and I'm with the Railroad Commission of Texas.
I'm an inspector based out of the Houston region,
and I've been with the Railroad Commission for six years.
My topic today is going to be
Navigating the Code: Liquid Basics.
Presentation is available at the following website link.
The Railroad Commission of Texas serves Texas
through our stewardship of natural resources
and the environment,
our concern for personal and community safety,
and our support of enhanced development
and economic vitality for the benefit of Texas.
From a historical perspective,
these are some of the past regulations
that shapes today's present pipeline,
hazardous liquid pipeline regulation:
Pipeline Inspection Protection Enforcement and Safety Act,
regarded as PIPES, of 2016;
Pipeline Safety Act of 2011;
Natural Gas Pipeline Safety Act of 1968, as amended;
Mineral Leasing Act,
which is a regulation to inspect on federal lands;
Section 5 of the International Bridge Act of 1972;
the Hazardous Liquid Pipeline Safety Act
of 1979, as amended.
This amendment actually amends Part 180
of the Hazardous Material Regulation,
which leads to the creation of CFR 195.
Regulations, these are some of the regulations
that are applicable to liquid pipelines:
49 CFR 195,
which is the Transportation of Hazardous Liquid by Pipeline;
49 CFR 194,
Response Plan for Onshore Oil Pipelines;
49 CFR 199, Drug and Alcohol Testing;
49 CFR 40, Procedure for Transportation Workplace
Drug and Alcohol Testing.
Both 49 CFR 199 and 49 CFR 40
actually creates requirement
for operators of hazardous liquid pipeline facilities
to have an anti-drug safety, anti-drug program
for employees who perform
certain safety-related functions on pipelines.
49 CFR 196,
which is the Protection of Underground Pipeline
from Excavation Activities,
and this prescribes just minimum requirement
that excavators must follow
to protect underground pipelines from excavation damage.
Texas Administrative Code Title 16 Part 1 Chapter 8,
which is the pipeline, the State Pipeline Safety Regulation;
Texas Administrative Code Title 16 Part 1 Chapter 18,
which is the Underground Pipeline Damage Prevention Program;
and HB 2982.
Some of the definitions
pertaining to hazardous liquid pipeline:
hazardous liquid means petroleum, petroleum product,
anhydrous ammonium, ethanol,
or other non-petroleum fuels,
including biofuels which is flammable, toxic,
or harmful to the environment
if released in significant quantities.
The addition of ethanol or other non-petroleum product
was part of the amendment which takes place
in July 1st of 2020
to the hazardous liquid pipeline rules.
So ethanol and petroleum product
was added as part of the definition in 2020.
Petroleum products means
flammable, toxic, or corrosive products
obtained from distilling and processing
of crude oils, unfinished oil,
NGL, blend stocks, or other hydrocarbons.
Pipes or pipeline systems, continuing on definitions, are...
The pipeline system is all parts of a pipeline facility
through which a hazardous liquid or carbon dioxide
move in the transportation,
but not limited to line pipes, valves, other appurtenances,
breakout tank, fabricated assemblies,
and simply put that the regulation
not just covers line pipe,
but they also cover the pipeline system.
The purpose of the regulation
is to establish safety regulation
for the design, operation, and maintain
of pipelines carrying hazardous material
and petroleum product in liquid form.
For complete understanding and application
of a particular section,
the section must be read in its entirety
from start to finish
and also notating punctuations.
And then operators are really required
to follow the sections that apply
to the pipeline that they install or operate.
Texas Administrative Code Title 16,
which is the Economic Regulation Part 1,
covers requirement for the Railroad Commission of Texas.
Chapter 8 covers the requirements
for pipeline safety regulation.
There are four Subchapters.
Subchapter A has general requirements,
Subchapter B, requirement for all pipelines,
Subchapter C, requirement for gas pipelines,
and then Subchapter D, requirement for hazardous liquid
and carbon dioxide pipelines only.
Subchapter B requirement, this is for all pipelines.
Within these Subchapters are rules
governing the Subchapters.
So as an example here, you have 8.51,
which covers the requirements for organization report,
such as P-5.
8.101, the integrity management requirement
for hazardous liquid pipelines
or even gas pipelines.
And this is one of the rule
where there is a federal requirement based on CFR 195.452
for integrity management affected pipelines
that are located in a High Consequence Area.
But there is also a Texas rule
for integrity management rules
that operators who do not have
pipelines in a High Consequence Area
also has to follow.
Then there is record keeping requirements.
8.110 covers the definition and requirement
of what is the gathering pipelines.
New construction...
8.125 covers the rules for waiver procedures,
and then 8.135, penalty guidelines for violations.
Subchapter D of the Texas Administrative Code
pretty much has four rules.
There is 8.301,
which is their record and reporting requirements,
such as accident report;
8.305, corrosion control requirement.
There is 8.310,
which covers the rules for public education
and liaison activities.
8.315 outline rules
for pipelines that are located 1,000 feet
of a public school or public facility.
Title 16 Part 1 Chapter 18, which is known
as the Underground Pipeline Damage Prevention,
and this applies and gives requirements
even in the case of exemption
for people or persons who engage in the movement of earth
in the vicinity of an underground pipeline
or underground hazardous pipeline.
It also covers the call center notification requirements.
House Bill HB 2982, and this relates to the power
or give the Railroad Commission of Texas
power to adopt and enforce safety standards
applicable to the transportation by pipelines
of hazardous liquid and carbon dioxide,
also for natural gas in rural locations.
49 CFR Part 195 from the federal regulation,
which is the
Transportation of Hazardous Liquid by Pipelines,
this regulation have eight subparts and three appendices.
You have Appendix A,
which pretty much gives demarcation
or outlines the separation
between the federal and state jurisdiction.
Appendix B gives guidance for risk-based alternative
to pressure testing of older pipes.
And then Appendix C gives guidance for implementation
of a integrity management program.
And the purpose of the regulation
is to establish safety standard
for the design, construction, operation, and maintenance
of pipelines carrying hazardous liquid.
An example here states,
which is on to the general Section 195.1,
which pipelines are covered by this part?
And an example here is any pipeline
that transport a highly volatile liquid.
Excepted examples in 195
are transportation of a hazardous liquid
transported in a gaseous state,
transportation of a hazardous liquid
through a pipeline by gravity.
However, as a part of the 2020 amendment,
there now is required,
there is requirement for annual reporting
for pipelines by gravity...
And then transportation of hazardous liquid
through low-stress pipelines.
195 subparts, they are...
These subparts include Subpart A,
which is general requirements;
Subpart B, annual, accident,
and safety reporting requirements;
Subpart C, which give general requirement for design;
Subpart D, construction;
Subpart E, pressure tests;
Subpart F, operation and maintenance.
Unlike the gas code,
the integrity management requirement
is embedded into Subpart F
of the hazardous liquid rule.
Subpart G, for operator qualification,
and then there is Subpart H
for corrosion control requirement.
Retroactive subparts of the federal regulation
are Subpart A, which is a general requirement,
Subpart B, Subpart F,
and Subpart H, which is corrosion control.
Non-retroactive subpart
are Subpart C, which covers design requirements;
Subpart D, construction;
Subpart E, pressure test;
Subpart G, operator qualification.
Pipeline examples...
49 CFR 195, the liquid pipelines...
Pipeline subparts are divided into...
Subpart 195 is divided into subparts
which addresses general topic.
And the general topic is then sometime further divided
into numbered section that addresses specific topic.
An example here is Subpart G,
which is operator qualification.
This subpart is then divided into 195.507,
which covers the requirements
for recordkeeping
for the Subpart G of the operator qualification.
Another examples of some of the subparts:
again, under the general subpart,
there are specific topics.
195.0
covers requirements for the scope,
what is covered under the scope of this subpart.
195.1, which pipeline is covered by this section.
195.2 is the definitions related to the general subpart.
195.3 also outlines what documents are incorporated
into the general subpart.
Each of the subparts, or some of the subparts,
has their own definition.
An example here, under Subpart A,
which is general requirement,
there's a definition for components,
which, a component mean any part of a pipeline
which may be subjected to pump pressure,
included but not limited to pipe, valves,
elbows, tees, flanges, and closure.
Gathering line definition is also included
into the general subpart.
195.3, incorporated by reference.
Again, this is a specific topic under the general subpart,
and this prescribes standards, or portions thereof,
incorporated by reference into this part
with the approval of the Director of the Federal Register.
So in other words, standards,
a whole standard can be incorporated into the regulation
and then becomes law.
Or a specific section of that standard
could be incorporated into the regulation
and then becomes, you know, law or a part of the code.
An example of a reference standard here
is ASME B31G-1991,
reaffirmed in 2004,
and this is the "Manual for Determining
the Remaining Strength of Corroded Pipelines."
Another example of a reference standard
that's incorporated into the regulation:
NACE SP0102
dash the 2010 version,
and this is a standard practice
for inline inspection of pipeline
and the revised March 13, 2010 version of that standard.
PIPES Act of 2016... And this is some of the
addition or the amendment to 49 CFR 195,
which actually takes place on July 1st of 2020.
And, again, just pointing out that the definition
now includes ethanol and biofuels.
195.13,
add annual reporting requirement to gravity line,
as stated earlier.
195.65, safety data sheet,
which is now required after a hazardous liquid leak
within six hours after the notification is given.
In other words, the operator has to provide onsite
federal and state coordinators with a safety data sheet
of the product that leaks.
Also, this has to be provided to any emergency personnel.
195.414, which now is under requirement
for inspection of pipeline
in areas affected by extreme weather, such as hurricane...
There is now a requirement
that pipelines that were part of
or was in the area subjected to any extreme weather
should be inspected at least 72
after the event has terminate.
There is also requirement 195.120
for inline inspection requirement.
There is 195.444,
which is now leak detection requirements.
So these are just some of the examples
that was put or amended the present code
to include some additional requirement.
And these takes effect as of July 1st, 2020.
Mandatory and non-mandatory statements:
shall, will, or must, these are mandatory.
They are imperative.
They are required to be followed by the regulation.
Should, could, or may is permitted to, authorized to.
They are a pretty much strong recommendation,
but they are not required to be followed.
The regulations are either prescriptive
and/or performance based.
Other term used to describe these regulation
are systemic or a specification.
Prescriptive regulation are typically easy to determine
compliance and course of action.
An example of this is once per calendar year,
not to exceed 15 months.
It give uniformity to the means of compliance.
The disadvantage of prescriptive regulation:
it pretty much is a cookie cutter.
It does not allow for variation in environment
and operating or physical characteristic,
does not state safety level,
and may require unnecessary costs,
the mere fact that you have to do the same type
or perform the same type of action
even on pipelines that are operating
in a different environment.
Performance-based regulation...
The advantage of these:
they allows for adaptation to individual situation,
encourage development of new equipment.
They are most economical solution to achieve safety
and promote safety and not just the letter of the law.
Disadvantage of performance-based regulation
is they are difficult to determine compliance.
Operator might not understand
their full requirements...
May create improper solution and safety problem.
They are more data intensive
with regards to risk analysis and assessment.
The liquid integrity rule...
The liquid integrity rules were put in place
to accelerate assessment of pipeline
in High Consequence Area,
and it's supposed to improve
the operator integrity management system.
They also improve the government role
in reviewing the adequacy of integrity program and plans
and provide increased public assurance in pipeline safety.
The integrity management process
pretty much includes threat identification.
It includes gathering, reviewing, and integration of data.
And this is also a constant process or a continual process.
It includes risk assessment.
It includes integrity assessment,
mitigation, and preventative and maintenance measure.
And, again, it's a continual update,
integrate, and review of data
to determine assessment schedules,
big picture of what is the dominant risk factors
on a pipeline.
The integrity management inspection protocol...
And this is from a generalized term.
These, the protocols that we use
to inspect operators from both the federal protocol
and state protocol, includes...
These are some of the topics
that are included in these protocol.
High Consequence Area segment identification...
There should be some baseline assessment.
There is an integrity assessment review,
remediation, risk analysis,
P&M measures.
And there is continual program evaluation
and assessment that's taking place.
And that completes my presentation.
And I'm open to questions.
Host: Doesn't look like
any questions have been submitted,
so I think you're good.
-: I'm good to go?
All right, folks, thanks again.
If there is no question,
well, each and every one of you have a good day.