Pipeline_ITM_Study_For_Contract_(2)_0003.pdf

Area/Equipment Group

Equipment Type Service/Purpose Regulatory Agency RAGAGEP/Best Practice RAGAGEP Section Applicable to: Federal Only/Private Only/Both

ITPM (Inspection Testing/Preventative Maintenance) Requirement

Pipeline Pipeline‐Main/Lateral lines Helium Transport PHMSA 49 CFR Part 192 Subpart A ‐ 192.5 N/A‐ due to Gas Composition

Class location must be determine for each gas transmission pipeline segment. Class 1 (lowest risk), 2, 3, 4 (highest risk) The class location is used to determine risk and affects maintenance activity frequency requirements.

Pipeline Pipeline‐Main/Lateral lines 3rd Party Damage prevention and monitoring

Best Practice 49 CFR Part 192 Subpart M ‐ 192.705 N/A‐ due to Gas Composition

Patrol right‐of‐way for indications of leaks, construction activity, and other factors affecting safety and operation

Pipeline Pipeline‐Main/Lateral lines Leak monitoring PHMSA 49 CFR Part 192 Subpart M ‐ 192.706 N/A‐ due to Gas Composition

Leakage surveys of pipeline must be conducted using leak detector equipment. (pipeline without an odor or odorant)

Pipeline Pipeline‐Main/Lateral lines

3rd Party Damage Prevention/Identificati on of pipeline for the public

Best Practice 49 CFR Part 192 Subpart M ‐ 192.707 Both Line markers are required at all road and railroad crossing and where needed to prevent possible damage.

Pipeline Pipeline‐Main/Lateral lines Corrosion Monitoring PHMSA 49 CFR Part 192 Subpart M ‐ 192.710 N/A‐ due to Gas Composition

Pipeline Assessment: An operator must perform initial assessments (In‐line‐inspection (ILI), Hydrotest, Guide Wave ultra‐ sonic (GWUT), or Direct Assessment) for all applicable pipeline segments no later than July 3, 2034.

Pipeline Relief Device Pressure Protection Best Practice 49 CFR Part 192 Subpart M ‐ 192.739 Both Relief Device: Inspect and test for mechanical condition, set pressure, capacity, reliability, installation, etc.

Pipeline Shutdown Valve Leak volume reduction

Best Practice 49 CFR Part 192 Subpart M ‐ 192.745 Both Pipeline valves inspection is required for all valves that might be required during any emergency.

Pipeline Cathodic Protection Corrosion Prevention Best Practice 49 CFR Part 192 Subpart I ‐ 192.465 a)

Both Cathodic Protection (CP) Annual Survey to determine whether the cathodic protection meets the requirements for the pipeline.

Pipeline Cathodic Protection Corrosion Prevention Best Practice 49 CFR Part 192 Subpart I ‐ 192.465 b)

Both Cathodic Protection (CP) Rectifier Survey ‐ CP rectifier or impressed current power source must be inspected.

Pipeline Cathodic Protection Corrosion Prevention Best Practice 49 CFR Part 192 Subpart I ‐ 192.465 c)

Both

Cathodic Protection: Each reverse current switch, each diode, and each interference bond whose failure would jeopardize structure protection must be electrically checked for proper performance.

Pipeline Cathodic Protection Corrosion Prevention Best Practice 49 CFR Part 192 Subpart I ‐ 192.481 Both Atmospheric Corrosion Monitoring: Inspect and evaluate each pipeline or portion of the pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion.

Pipeline Procedures

Identify Maintenance and Operations Requirements & Information

PHMSA 49 CFR Part 192 Subpart L ‐ 192.605 Both

Operations and Maintenance (O&M) Plan: A manual of written procedures for conducting operations and maintenance activities, abnormal operations and for emergency response.

Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted

Pipeline Procedures

3rd Party Damage Prevention/Identificati on of pipeline for the public

Best Practice 49 CFR Part 192 Subpart L ‐ 192.614 Both Damage Prevention Program: each operator of a buried pipeline must carry out a written program to prevent damage to that pipeline from excavation activities and 3rd party damage.

Pipeline Procedures Procedure PHMSA 49 CFR Part 192 Subpart L ‐ 192.615 N/A‐ due to Gas Composition

Emergency Plans: Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. (Identification of emergency, notifications, emergency shutdown, availability of equipment, tools, material and personnel to respond to the emergency, training, etc.

Pipeline Procedures Procedure PHMSA 49 CFR Part 192 Subpart L ‐ 192.616

& API‐RP‐1162

N/A‐ due to Gas Composition

Public Awareness: Each pipeline operator must develop and implement a written continuing public education program that follows the guidance provided in the API‐RP‐1162. The operator's program must specifically include provisions to educate the public, appropriate government organizations, and persons engaged in excavation related activities.

Pipeline Procedures Management of Change

Best Practice ASME 31.8S 31.8S.11 Both Formal management of change procedures shall be developed in order to identify and consider the impact of changes to pipeline systems and their integrity.

Pipeline Reports Incident Reporting PHMSA 49 CFR Part 191 191.15 N/A‐ due to Gas Composition

Incident Reports: Each operator must submit DOT Form PHMSA F 7100.2 as soon as practicable but not more than 30 days after detection of an incident.

Pipeline Reports Annual Report PHMSA 49 CFR Part 191 191.15 N/A‐ due to Gas Composition

Annual Report: Each operator must submit an annual report for that system on DOT Form PHMSA F 7100.2‐1.

Pipeline Qualifications & Training Qualifications & Training

PHMSA 49 CFR 192 Subpart N N/A‐ due to Gas Composition

Operator Qualification (OQ) Program: Minimum requirements for qualification of individuals performing covered operations/maintenance tasks on a pipeline facility.

Metering Building Gas Analyzers Process Gas Composition to Cliffside Plant

Best Practice OEM Recommenation

OEM

Recommendation

Both Calibration and filter change of GC analyzer per manufacture recommendations

Metering Building Gas Analyzers Process Gas Composition to Cliffside Plant

Best Practice OEM Recommendation

OEM

Recommendation

Both Calibration and testing of O2 and LEL Detectors in GC buildings

Pipeline GC Analyzers Gas Composition in Pipeline

Best Practice OEM Recommendation

OEM

Recommendation

Both Calibration and filter change of GC analyzer per manufacture recommendations

Pipeline GC Analyzers Gas Composition in Pipeline

Best Practice OEM Recommendation

OEM

Recommendation

Both Calibration and testing of O2 and LEL Detectors in GC buildings

Wellhead / Gathering

Underground Gas Storage Permit TX RRC 16 TAC 3 Statewide Rule 96.b Private Only No person may operate a gas storage facility without obtaining a permit from the TRRC

Wellhead / Gathering

Underground Gas Storage Ownership Transfer

FORM P‐4

TX RRC 16 TAC 3 Statewide Rule 96.h Private Only A storage facility permit may not be transferred without written notice to TRRC at least 15 days prior to transfer date and if no TRCC objection is received prior to transfer date.

Wellhead / Gathering

Injection/Withdrawal Wells Leak Detection TX RRC 16 TAC 3 Statewide Rule 3.96.i.1

Private Only Leak detection is required for each gas storage well located within 100 yards of a residence, commercial establishment, or public area.

Wellhead / Gathering

Injection/Withdrawal Wells Warning Systems & Alarms

TX RRC 16 TAC 3

Statewide Rule 3.96.i.2

Private Only If leak detector required, an integrated warning system is required that is audible and visible in control room or remote control center.

Wellhead / Gathering

Injection/Withdrawal Wells Facility Emergency Response Plan

TX RRC 16 TAC 3

Statewide Rule 3.96.i.3 Private Only Emergency Response Plan shall be submitted to TRRC.

Wellhead / Gathering

Injection/Withdrawal Wells Employee and Contractor Safety Training

TX RRC 16 TAC 3

Statewide Rule 3.96.i.4 Private Only

Prepare and implement operational safety training for each employee at facility and contractors on operational safety

Wellhead / Gathering

Injection/withdrawal well Operating Pressure TX RRC 16 TAC 3 Statewide Rule 3.96.n.1 Private Only

Wellhead pressure. Wellhead pressure of each storage well shall be recorded, monitored electronically, or controlled by a preset high‐low pressure sensor switch.

Wellhead / Gathering

Injection/withdrawal well Monitoring Requirements

TX RRC 16 TAC 3

Statewide Rule 3.96.n.2 Private Only

Pressure reporting. Wellhead pressure information for each storage well shall be reportted to TRRC.

Wellhead / Gathering

Injection/withdrawal well Monitoring Requirements

TX RRC 16 TAC 3

Statewide Rule 3.96.l.2 Private Only

Pressure observation valves. The wellhead shall be equipped with a pressure observation valve on the tubing and each casing annulus so that a gauge may be installed for pressure monitoring.

Metering Building Metering Monitoring Requirements

TX RRC 16 TAC 3

Statewide Rule 3.96.n.3 Private Only

Gas metering. The total volume of gas injected into and withdrawn from each storage project shall be metered through a master meter.

Wellhead / Gathering

Injection/withdrawal well Reporting Requirements

TX RRC 16 TAC 3

Statewide Rule 3.96.n.5 Private Only

Reporting of leaks. The operator shall report to the district office, any pressure changes or other monitoring data that indicate a leak in the well or lack of confinement of injected gases in the storage reservoir.

Wellhead / Gathering

Injection/withdrawal well Record Retention TX RRC 16 TAC 3

Statewide Rule 3.96.n.4 Private Only

Record retention. All wellhead pressure records, gas metering records and leak detector results (if appliacble) shall be retained by operator.

Wellhead / Gathering

Injection well only Testing & Maintenance

TX RRC 16 TAC 3

Statewide Rule 3.96.o.2 Private Only

Each gas storage well shall be tested for integrity. Pressure test long string casing, or tubing‐casing if well is equiped with tubing set in a packer. Gas storage well where injection is through casing shall test at maximum authorized injection pressure. If injection is thorugh tubing and packer, the well shall be tested at no less than 500 psig.

Wellhead / Gathering

Injection well only Testing & Maintenance

TX RRC 16 TAC 3

Statewide Rule 3.96.o.3

Private Only Alternative to testing ‐ monitor tubing‐casing annulus pressure, provided there is no indicaito of problems with well.

Wellhead / Gathering

Injection well only Testing & Maintenance

TX RRC 16 TAC 3

Statewide Rule 3.96.o.4 Private Only

The operator shall notify the district office prior to conducting any integrity test.

Wellhead / Gathering

Injection well only Testing & Maintenance

TX RRC 16 TAC 3

Statewide Rule 3.96.o.5 Private Only

A complete record of each integrity test shall be filed in duplicate with the district office .

Wellhead / Gathering

Injection/withdrawal well Plugging TX RRC 16 TAC 3 Statewide Rule 3.96.p

Private Only A gas storage well shall be plugged upon abandonment in accordance to §3.14 ‐ Plugging.

Wellhead / Gathering

Injection/withdrawal well Well Cellar TX RRC n/a n/a n/a Not regulated

Wellhead / Gathering

Drip Station Aboveground Storage Tank

Oily water from drip stations.

TX RRC 16 TAC 3

Statewide Rule 3.8.f & 3.8.g

Private Only

Oil and gas waste transporter must have TRRC O&G waste hauler permit.

Recordkeeping ‐ keep the following information for 3 years: BLM storage location, disposal facility, hauler name & permit No., type & volume of waste; may be in the form of run ticket, invoice, or other.

Pipeline (main) Asbestos‐wrapped Pipeline Asbestos Containing Material Disposal

TCEQ 30 TAC 330 171.c.3&4 Both

Management and disposal options for special waste:

1. Asbestos: There are two types of asbestos waste—regulated

(friable) and non‐regulated (not friable) asbestos‐containing material (RACM and non‐RACM) as defined in 40 CFR Part 61 Section 141. Also, the amount of asbestos in the material contributes to the type of asbestos waste. Non‐RACM may become RACM if subject to sanding, grinding, cutting, or abrading, or it has a high probability of being reduced to powder during demolition or renovation.

a. RACM is friable asbestos‐containing material that contains greater than 1 percent asbestos. Friable is defined as asbestos containing material that, when dry, can be crushed to a powder by hand pressure. RACM may be disposed of at a Type I or Type I arid exempt (AE) MSW landfill in accordance with 30 TAC 330.171(c)(3).

b. Non‐RACM is material containing less than one percent asbestos or non‐friable asbestos‐containing material not identified as regulated. Non‐RACM may be disposed of at any MSW landfill provided the facility is authorized to accept the waste in accordance with 30 TAC 330.171(c)(4).

Pipeline (main) Asbestos‐wrapped Pipeline Asbestos Abatement USEPA NESHAP Subpart M Both

If exposing 260 linear feet of pipe to atmosphere for maintenance activities, ensure operations follow the NESHAP Subpart M requirements of emissions abatement (wetting pipeline, sealing exposed pipeline in leak‐proof material, proper disposal)

Wellhead / Gathering

Piping Maintenance / Startup / Shutdown

TCEQ

30 Part 1 Ch. 106 Subchapter O

RULE §106.355/106.3 Both Maintain records of any Maintenance/Startup/Shutdown (MSS) venting and obtain permit prior to venting if uncontrolled emissions would exceed 1 tpy VOC or NOx