WEBVTT
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Evon, you're good to
go ahead and get started.
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Okay, sounds good.
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Hello, good afternoon.
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My name is Evon Boothe,
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and I'm with the Railroad
Commission of Texas.
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I'm an inspector based
out of the Houston region,
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and I've been with the Railroad
Commission for six years.
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My topic today is going to be
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Navigating the Code: Liquid Basics.
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Presentation is available
at the following website link.
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The Railroad Commission
of Texas serves Texas
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through our stewardship
of natural resources
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and the environment,
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our concern for personal
and community safety,
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and our support of enhanced development
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and economic vitality
for the benefit of Texas.
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From a historical perspective,
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these are some of the past regulations
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that shapes today's present pipeline,
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hazardous liquid pipeline regulation:
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Pipeline Inspection Protection
Enforcement and Safety Act,
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regarded as PIPES, of 2016;
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Pipeline Safety Act of 2011;
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Natural Gas Pipeline Safety
Act of 1968, as amended;
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Mineral Leasing Act,
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which is a regulation to
inspect on federal lands;
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Section 5 of the International
Bridge Act of 1972;
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the Hazardous Liquid Pipeline Safety Act
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of 1979, as amended.
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This amendment actually amends Part 180
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of the Hazardous Material Regulation,
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which leads to the creation of CFR 195.
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Regulations, these are
some of the regulations
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that are applicable to liquid pipelines:
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49 CFR 195,
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which is the Transportation of
Hazardous Liquid by Pipeline;
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49 CFR 194,
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Response Plan for Onshore Oil Pipelines;
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49 CFR 199, Drug and Alcohol Testing;
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49 CFR 40, Procedure for
Transportation Workplace
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Drug and Alcohol Testing.
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Both 49 CFR 199 and 49 CFR 40
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actually creates requirement
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for operators of hazardous
liquid pipeline facilities
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to have an anti-drug
safety, anti-drug program
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for employees who perform
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certain safety-related
functions on pipelines.
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49 CFR 196,
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which is the Protection
of Underground Pipeline
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from Excavation Activities,
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and this prescribes just
minimum requirement
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that excavators must follow
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to protect underground
pipelines from excavation damage.
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Texas Administrative Code
Title 16 Part 1 Chapter 8,
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which is the pipeline, the
State Pipeline Safety Regulation;
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Texas Administrative Code
Title 16 Part 1 Chapter 18,
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which is the Underground Pipeline
Damage Prevention Program;
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and HB 2982.
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Some of the definitions
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pertaining to hazardous liquid pipeline:
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hazardous liquid means
petroleum, petroleum product,
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anhydrous ammonium, ethanol,
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or other non-petroleum fuels,
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including biofuels
which is flammable, toxic,
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or harmful to the environment
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if released in significant quantities.
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The addition of ethanol or
other non-petroleum product
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was part of the amendment
which takes place
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in July 1st of 2020
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to the hazardous liquid pipeline rules.
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So ethanol and petroleum product
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was added as part of
the definition in 2020.
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Petroleum products means
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flammable, toxic, or corrosive products
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obtained from distilling and processing
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of crude oils, unfinished oil,
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NGL, blend stocks,
or other hydrocarbons.
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Pipes or pipeline systems,
continuing on definitions, are...
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The pipeline system is
all parts of a pipeline facility
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through which a hazardous
liquid or carbon dioxide
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move in the transportation,
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but not limited to line pipes,
valves, other appurtenances,
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breakout tank, fabricated assemblies,
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and simply put that the regulation
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not just covers line pipe,
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but they also cover the pipeline system.
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The purpose of the regulation
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is to establish safety regulation
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for the design, operation, and maintain
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of pipelines carrying hazardous material
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and petroleum product in liquid form.
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For complete
understanding and application
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of a particular section,
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the section must be read in its entirety
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from start to finish
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and also notating punctuations.
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And then operators are really required
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to follow the sections that apply
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to the pipeline that
they install or operate.
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Texas Administrative Code Title 16,
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which is the Economic Regulation Part 1,
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covers requirement for the
Railroad Commission of Texas.
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Chapter 8 covers the requirements
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for pipeline safety regulation.
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There are four Subchapters.
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Subchapter A has general requirements,
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Subchapter B,
requirement for all pipelines,
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Subchapter C, requirement
for gas pipelines,
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and then Subchapter D,
requirement for hazardous liquid
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and carbon dioxide pipelines only.
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Subchapter B requirement,
this is for all pipelines.
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Within these Subchapters are rules
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governing the Subchapters.
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So as an example here, you have 8.51,
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which covers the requirements
for organization report,
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such as P-5.
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8.101, the integrity
management requirement
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for hazardous liquid pipelines
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or even gas pipelines.
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And this is one of the rule
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where there is a federal
requirement based on CFR 195.452
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for integrity management
affected pipelines
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that are located in a
High Consequence Area.
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But there is also a Texas rule
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for integrity management rules
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that operators who do not have
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pipelines in a High Consequence Area
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also has to follow.
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Then there is record
keeping requirements.
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8.110 covers the
definition and requirement
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of what is the gathering pipelines.
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New construction...
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8.125 covers the rules
for waiver procedures,
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and then 8.135, penalty
guidelines for violations.
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Subchapter D of the
Texas Administrative Code
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pretty much has four rules.
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There is 8.301,
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which is their record and
reporting requirements,
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such as accident report;
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8.305, corrosion control requirement.
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There is 8.310,
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which covers the rules
for public education
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and liaison activities.
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8.315 outline rules
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for pipelines that
are located 1,000 feet
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of a public school or public facility.
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Title 16 Part 1 Chapter
18, which is known
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as the Underground
Pipeline Damage Prevention,
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and this applies and gives requirements
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even in the case of exemption
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for people or persons who
engage in the movement of earth
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in the vicinity of an
underground pipeline
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or underground hazardous pipeline.
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It also covers the call center
notification requirements.
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House Bill HB 2982, and
this relates to the power
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or give the Railroad Commission of Texas
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power to adopt and
enforce safety standards
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applicable to the
transportation by pipelines
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of hazardous liquid and carbon dioxide,
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also for natural gas in rural locations.
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49 CFR Part 195 from
the federal regulation,
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which is the
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Transportation of
Hazardous Liquid by Pipelines,
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this regulation have eight
subparts and three appendices.
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You have Appendix A,
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which pretty much gives demarcation
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or outlines the separation
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between the federal
and state jurisdiction.
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Appendix B gives guidance
for risk-based alternative
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to pressure testing of older pipes.
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And then Appendix C gives
guidance for implementation
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of a integrity management program.
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And the purpose of the regulation
00:10:20.370 --> 00:10:22.390
is to establish safety standard
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for the design, construction,
operation, and maintenance
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of pipelines carrying hazardous liquid.
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An example here states,
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which is on to the
general Section 195.1,
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which pipelines are
covered by this part?
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And an example here is any pipeline
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that transport a highly volatile liquid.
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Excepted examples in 195
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are transportation of a hazardous liquid
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transported in a gaseous state,
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transportation of a hazardous liquid
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through a pipeline by gravity.
00:11:02.780 --> 00:11:07.780
However, as a part of
the 2020 amendment,
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there now is required,
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there is requirement
for annual reporting
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for pipelines by gravity...
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And then transportation
of hazardous liquid
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through low-stress pipelines.
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195 subparts, they are...
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These subparts include Subpart A,
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which is general requirements;
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Subpart B, annual, accident,
00:11:37.020 --> 00:11:39.782
and safety reporting requirements;
00:11:39.782 --> 00:11:43.770
Subpart C, which give
general requirement for design;
00:11:43.770 --> 00:11:46.391
Subpart D, construction;
00:11:46.391 --> 00:11:48.770
Subpart E, pressure tests;
00:11:48.770 --> 00:11:52.220
Subpart F, operation and maintenance.
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Unlike the gas code,
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the integrity management requirement
00:12:00.580 --> 00:12:03.490
is embedded into Subpart F
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of the hazardous liquid rule.
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Subpart G, for operator qualification,
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and then there is Subpart H
00:12:12.710 --> 00:12:15.563
for corrosion control requirement.
00:12:16.570 --> 00:12:18.730
Retroactive subparts
of the federal regulation
00:12:18.730 --> 00:12:22.034
are Subpart A, which
is a general requirement,
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Subpart B, Subpart F,
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and Subpart H, which
is corrosion control.
00:12:29.160 --> 00:12:30.450
Non-retroactive subpart
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are Subpart C, which
covers design requirements;
00:12:34.968 --> 00:12:36.931
Subpart D, construction;
00:12:36.931 --> 00:12:39.066
Subpart E, pressure test;
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Subpart G, operator qualification.
00:12:43.030 --> 00:12:45.418
Pipeline examples...
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49 CFR 195, the liquid pipelines...
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Pipeline subparts are divided into...
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Subpart 195 is divided into subparts
00:12:58.210 --> 00:13:01.430
which addresses general topic.
00:13:01.430 --> 00:13:06.430
And the general topic is
then sometime further divided
00:13:06.450 --> 00:13:11.010
into numbered section
that addresses specific topic.
00:13:11.010 --> 00:13:13.750
An example here is Subpart G,
00:13:13.750 --> 00:13:15.883
which is operator qualification.
00:13:17.020 --> 00:13:21.370
This subpart is then
divided into 195.507,
00:13:21.370 --> 00:13:26.370
which covers the requirements
00:13:27.080 --> 00:13:27.930
for recordkeeping
00:13:29.883 --> 00:13:34.883
for the Subpart G of
the operator qualification.
00:13:37.384 --> 00:13:40.290
Another examples of
some of the subparts:
00:13:40.290 --> 00:13:43.934
again, under the general subpart,
00:13:43.934 --> 00:13:45.470
there are specific topics.
00:13:45.470 --> 00:13:48.160
195.0
00:13:49.822 --> 00:13:51.760
covers requirements for the scope,
00:13:51.760 --> 00:13:56.110
what is covered under
the scope of this subpart.
00:13:56.110 --> 00:14:00.480
195.1, which pipeline is
covered by this section.
00:14:00.480 --> 00:14:05.480
195.2 is the definitions
related to the general subpart.
00:14:07.510 --> 00:14:12.510
195.3 also outlines what
documents are incorporated
00:14:13.820 --> 00:14:16.040
into the general subpart.
00:14:19.380 --> 00:14:23.040
Each of the subparts,
or some of the subparts,
00:14:23.040 --> 00:14:24.380
has their own definition.
00:14:24.380 --> 00:14:26.890
An example here, under Subpart A,
00:14:26.890 --> 00:14:28.563
which is general requirement,
00:14:29.650 --> 00:14:32.010
there's a definition for components,
00:14:32.010 --> 00:14:35.340
which, a component
mean any part of a pipeline
00:14:35.340 --> 00:14:38.280
which may be subjected to pump pressure,
00:14:38.280 --> 00:14:41.840
included but not
limited to pipe, valves,
00:14:41.840 --> 00:14:45.640
elbows, tees, flanges, and closure.
00:14:45.640 --> 00:14:48.890
Gathering line
definition is also included
00:14:48.890 --> 00:14:51.223
into the general subpart.
00:14:56.160 --> 00:14:59.530
195.3, incorporated by reference.
00:14:59.530 --> 00:15:04.530
Again, this is a specific topic
under the general subpart,
00:15:05.700 --> 00:15:10.070
and this prescribes
standards, or portions thereof,
00:15:10.070 --> 00:15:13.810
incorporated by reference into this part
00:15:13.810 --> 00:15:17.620
with the approval of the
Director of the Federal Register.
00:15:17.620 --> 00:15:21.080
So in other words, standards,
00:15:21.080 --> 00:15:25.560
a whole standard can be
incorporated into the regulation
00:15:25.560 --> 00:15:26.993
and then becomes law.
00:15:29.626 --> 00:15:32.040
Or a specific section of that standard
00:15:32.040 --> 00:15:36.550
could be incorporated
into the regulation
00:15:36.550 --> 00:15:41.063
and then becomes, you
know, law or a part of the code.
00:15:42.320 --> 00:15:45.890
An example of a reference standard here
00:15:45.890 --> 00:15:48.067
is ASME B31G-1991,
00:15:52.180 --> 00:15:54.330
reaffirmed in 2004,
00:15:54.330 --> 00:15:56.860
and this is the "Manual for Determining
00:15:56.860 --> 00:15:59.627
the Remaining Strength
of Corroded Pipelines."
00:16:01.060 --> 00:16:03.690
Another example of a reference standard
00:16:03.690 --> 00:16:07.580
that's incorporated into the regulation:
00:16:07.580 --> 00:16:08.850
NACE SP0102
00:16:11.370 --> 00:16:14.290
dash the 2010 version,
00:16:14.290 --> 00:16:15.840
and this is a standard practice
00:16:15.840 --> 00:16:18.270
for inline inspection of pipeline
00:16:18.270 --> 00:16:23.270
and the revised March 13,
2010 version of that standard.
00:16:25.770 --> 00:16:29.570
PIPES Act of 2016...
And this is some of the
00:16:33.310 --> 00:16:36.497
addition or the amendment to 49 CFR 195,
00:16:38.660 --> 00:16:43.660
which actually takes
place on July 1st of 2020.
00:16:45.864 --> 00:16:48.870
And, again, just pointing
out that the definition
00:16:48.870 --> 00:16:51.980
now includes ethanol and biofuels.
00:16:51.980 --> 00:16:54.723
195.13,
00:16:56.490 --> 00:17:00.070
add annual reporting
requirement to gravity line,
00:17:00.070 --> 00:17:01.450
as stated earlier.
00:17:01.450 --> 00:17:06.280
195.65, safety data sheet,
00:17:06.280 --> 00:17:10.260
which is now required
after a hazardous liquid leak
00:17:10.260 --> 00:17:15.170
within six hours after
the notification is given.
00:17:15.170 --> 00:17:19.870
In other words, the
operator has to provide onsite
00:17:21.390 --> 00:17:25.370
federal and state coordinators
with a safety data sheet
00:17:25.370 --> 00:17:26.570
of the product that leaks.
00:17:26.570 --> 00:17:31.570
Also, this has to be provided
to any emergency personnel.
00:17:33.400 --> 00:17:37.980
195.414, which now is under requirement
00:17:37.980 --> 00:17:40.130
for inspection of pipeline
00:17:40.130 --> 00:17:44.810
in areas affected by extreme
weather, such as hurricane...
00:17:44.810 --> 00:17:46.330
There is now a requirement
00:17:46.330 --> 00:17:50.430
that pipelines that were part of
00:17:50.430 --> 00:17:53.710
or was in the area subjected
to any extreme weather
00:17:53.710 --> 00:17:55.680
should be inspected at least 72
00:17:55.680 --> 00:17:59.220
after the event has terminate.
00:17:59.220 --> 00:18:02.930
There is also requirement 195.120
00:18:02.930 --> 00:18:06.103
for inline inspection requirement.
00:18:07.970 --> 00:18:10.487
There is 195.444,
00:18:13.660 --> 00:18:16.540
which is now leak
detection requirements.
00:18:16.540 --> 00:18:18.990
So these are just some of the examples
00:18:18.990 --> 00:18:23.780
that was put or amended the present code
00:18:23.780 --> 00:18:26.390
to include some additional requirement.
00:18:26.390 --> 00:18:31.247
And these takes effect
as of July 1st, 2020.
00:18:33.120 --> 00:18:35.620
Mandatory and non-mandatory statements:
00:18:35.620 --> 00:18:39.630
shall, will, or must,
these are mandatory.
00:18:39.630 --> 00:18:40.640
They are imperative.
00:18:40.640 --> 00:18:43.750
They are required to be
followed by the regulation.
00:18:43.750 --> 00:18:48.080
Should, could, or may is
permitted to, authorized to.
00:18:48.080 --> 00:18:50.820
They are a pretty much
strong recommendation,
00:18:50.820 --> 00:18:52.870
but they are not
required to be followed.
00:18:55.069 --> 00:18:57.430
The regulations are either prescriptive
00:18:57.430 --> 00:18:59.910
and/or performance based.
00:18:59.910 --> 00:19:02.180
Other term used to
describe these regulation
00:19:02.180 --> 00:19:05.453
are systemic or a specification.
00:19:06.580 --> 00:19:10.020
Prescriptive regulation are
typically easy to determine
00:19:10.020 --> 00:19:12.400
compliance and course of action.
00:19:12.400 --> 00:19:15.777
An example of this is
once per calendar year,
00:19:15.777 --> 00:19:17.343
not to exceed 15 months.
00:19:18.440 --> 00:19:23.020
It give uniformity to the
means of compliance.
00:19:23.020 --> 00:19:26.184
The disadvantage of
prescriptive regulation:
00:19:26.184 --> 00:19:27.970
it pretty much is a cookie cutter.
00:19:27.970 --> 00:19:31.340
It does not allow for
variation in environment
00:19:31.340 --> 00:19:34.380
and operating or
physical characteristic,
00:19:34.380 --> 00:19:37.020
does not state safety level,
00:19:37.020 --> 00:19:39.800
and may require unnecessary costs,
00:19:39.800 --> 00:19:42.470
the mere fact that you
have to do the same type
00:19:43.397 --> 00:19:45.620
or perform the same type of action
00:19:45.620 --> 00:19:48.100
even on pipelines that are operating
00:19:48.100 --> 00:19:49.713
in a different environment.
00:19:50.680 --> 00:19:52.640
Performance-based regulation...
00:19:52.640 --> 00:19:53.840
The advantage of these:
00:19:53.840 --> 00:19:58.320
they allows for adaptation
to individual situation,
00:19:58.320 --> 00:20:01.540
encourage development of new equipment.
00:20:01.540 --> 00:20:05.960
They are most economical
solution to achieve safety
00:20:05.960 --> 00:20:08.993
and promote safety and
not just the letter of the law.
00:20:10.620 --> 00:20:13.050
Disadvantage of
performance-based regulation
00:20:13.050 --> 00:20:15.950
is they are difficult to
determine compliance.
00:20:15.950 --> 00:20:17.920
Operator might not understand
00:20:19.370 --> 00:20:23.330
their full requirements...
00:20:23.330 --> 00:20:26.590
May create improper
solution and safety problem.
00:20:26.590 --> 00:20:27.990
They are more data intensive
00:20:29.846 --> 00:20:32.663
with regards to risk
analysis and assessment.
00:20:36.486 --> 00:20:38.630
The liquid integrity rule...
00:20:38.630 --> 00:20:42.780
The liquid integrity
rules were put in place
00:20:42.780 --> 00:20:45.680
to accelerate assessment of pipeline
00:20:45.680 --> 00:20:47.920
in High Consequence Area,
00:20:47.920 --> 00:20:49.380
and it's supposed to improve
00:20:49.380 --> 00:20:52.220
the operator integrity
management system.
00:20:52.220 --> 00:20:55.620
They also improve the government role
00:20:55.620 --> 00:20:59.280
in reviewing the adequacy
of integrity program and plans
00:21:00.200 --> 00:21:04.423
and provide increased public
assurance in pipeline safety.
00:21:05.350 --> 00:21:07.880
The integrity management process
00:21:09.170 --> 00:21:13.190
pretty much includes
threat identification.
00:21:13.190 --> 00:21:17.600
It includes gathering,
reviewing, and integration of data.
00:21:17.600 --> 00:21:21.330
And this is also a constant
process or a continual process.
00:21:21.330 --> 00:21:23.490
It includes risk assessment.
00:21:23.490 --> 00:21:25.583
It includes integrity assessment,
00:21:26.920 --> 00:21:30.960
mitigation, and preventative
and maintenance measure.
00:21:30.960 --> 00:21:33.300
And, again, it's a continual update,
00:21:33.300 --> 00:21:35.250
integrate, and review of data
00:21:35.250 --> 00:21:38.243
to determine assessment schedules,
00:21:40.250 --> 00:21:44.390
big picture of what is
the dominant risk factors
00:21:44.390 --> 00:21:45.403
on a pipeline.
00:21:46.710 --> 00:21:51.710
The integrity management
inspection protocol...
00:21:52.340 --> 00:21:56.160
And this is from a generalized term.
00:21:56.160 --> 00:21:58.980
These, the protocols that we use
00:21:58.980 --> 00:22:02.320
to inspect operators from
both the federal protocol
00:22:02.320 --> 00:22:06.570
and state protocol, includes...
00:22:06.570 --> 00:22:09.400
These are some of the topics
00:22:09.400 --> 00:22:11.980
that are included in these protocol.
00:22:11.980 --> 00:22:15.540
High Consequence Area
segment identification...
00:22:15.540 --> 00:22:18.870
There should be some
baseline assessment.
00:22:18.870 --> 00:22:21.820
There is an integrity assessment review,
00:22:21.820 --> 00:22:25.773
remediation, risk analysis,
00:22:26.670 --> 00:22:28.640
P&M measures.
00:22:28.640 --> 00:22:33.620
And there is continual
program evaluation
00:22:33.620 --> 00:22:36.803
and assessment that's taking place.
00:22:38.150 --> 00:22:42.060
And that completes my presentation.
00:22:42.060 --> 00:22:44.853
And I'm open to questions.
00:23:18.300 --> 00:23:19.133
Doesn't look like
00:23:19.133 --> 00:23:20.310
any questions have been submitted,
00:23:20.310 --> 00:23:22.285
so I think you're good.
00:23:22.285 --> 00:23:23.135
I'm good to go?
00:23:29.390 --> 00:23:31.770
All right, folks, thanks again.
00:23:31.770 --> 00:23:33.960
If there is no question,
00:23:33.960 --> 00:23:36.360
well, each and every one
of you have a good day.