WEBVTT 00:00:06.836 --> 00:00:09.580 All right, good morning, everyone. 00:00:09.580 --> 00:00:13.040 I have nine o'clock on the clock 00:00:13.040 --> 00:00:14.890 I'm going through and looking at right now, 00:00:14.890 --> 00:00:16.750 and it seems like we've had a decent amount of people 00:00:16.750 --> 00:00:17.960 go through and join in. 00:00:17.960 --> 00:00:21.430 So, welcome to the presentation 00:00:21.430 --> 00:00:24.620 on the Railroad Commission, Pipeline Safety, 00:00:24.620 --> 00:00:27.580 specialized pipeline inspections. 00:00:27.580 --> 00:00:29.330 A couple of housekeeping items 00:00:29.330 --> 00:00:31.770 before we go through and get to the presenters 00:00:31.770 --> 00:00:33.870 to go through and talk about their topics. 00:00:35.740 --> 00:00:38.870 First off, please do know that 00:00:38.870 --> 00:00:41.260 this PowerPoint is ready for download. 00:00:41.260 --> 00:00:43.190 If you go to the RRC website, 00:00:43.190 --> 00:00:45.550 go through and follow the link right here, 00:00:45.550 --> 00:00:46.710 that's on the slide. 00:00:46.710 --> 00:00:48.610 It should also go through and be posted 00:00:48.610 --> 00:00:52.540 in the Q&A section of the Zoom meeting. 00:00:52.540 --> 00:00:54.190 So you should be able to find it there as well. 00:00:54.190 --> 00:00:57.224 So you can go through and do as a simple copy and paste 00:00:57.224 --> 00:00:58.057 and all of that. 00:00:58.057 --> 00:00:59.920 So if you know that you can go through and get ahold of that 00:00:59.920 --> 00:01:01.580 to go through and follow along with us 00:01:01.580 --> 00:01:03.790 or just to go through and have it after the presentation 00:01:03.790 --> 00:01:04.623 is over with. 00:01:07.100 --> 00:01:09.590 So, to go through and kind of get us started 00:01:09.590 --> 00:01:11.260 and get us gonna know what's going on 00:01:11.260 --> 00:01:12.730 with all this right here, 00:01:12.730 --> 00:01:15.330 whenever we go through and do specialized inspections, 00:01:15.330 --> 00:01:16.870 one thing that the Railroad Commission 00:01:16.870 --> 00:01:18.880 always likes to try to go and do, 00:01:18.880 --> 00:01:22.170 is make sure that whenever we go through and call anyone, 00:01:22.170 --> 00:01:24.960 if you, your company is a subsidiary of your company's, 00:01:24.960 --> 00:01:26.410 anything along those lines, 00:01:26.410 --> 00:01:28.150 we wanna make sure that we get everybody 00:01:28.150 --> 00:01:31.250 that's underneath the umbrella of that specific plan 00:01:31.250 --> 00:01:33.440 that we're going through and talking about. 00:01:33.440 --> 00:01:35.660 That way we can go through and kind of 00:01:35.660 --> 00:01:37.410 cut down on the number of inspections 00:01:37.410 --> 00:01:38.243 and the number of times 00:01:38.243 --> 00:01:39.540 we had to go through and meet with you 00:01:39.540 --> 00:01:41.740 or others in your company. 00:01:41.740 --> 00:01:45.223 So, let's say, for example, you go through and have, 00:01:46.350 --> 00:01:47.970 four or five different companies 00:01:47.970 --> 00:01:49.810 under your little umbrella that you have 00:01:49.810 --> 00:01:52.210 for whatever reasons you go through and have them. 00:01:52.210 --> 00:01:54.270 We wanna make sure that we get all four or five of those 00:01:54.270 --> 00:01:55.320 done at one time, 00:01:55.320 --> 00:01:57.290 that way we don't have to go through and see you 00:01:57.290 --> 00:01:58.980 four or five different times 00:01:58.980 --> 00:02:01.340 and be looking at the same thing over and over again, 00:02:01.340 --> 00:02:03.240 that we've already seen. 00:02:03.240 --> 00:02:04.940 So whenever an inspector from our group 00:02:04.940 --> 00:02:06.270 goes through and calls you, 00:02:06.270 --> 00:02:08.220 and asks, "Hey, I want to go through and do 00:02:08.220 --> 00:02:11.490 a specialized operator qualification inspection," 00:02:11.490 --> 00:02:13.737 let them know right there on the phone when they call you, 00:02:13.737 --> 00:02:14.700 "Hey, by the way, 00:02:14.700 --> 00:02:17.660 I've got all these different companies right here as well. 00:02:17.660 --> 00:02:19.920 Can we get them all done at one time?" 00:02:19.920 --> 00:02:20.890 We wanna go through and do that 00:02:20.890 --> 00:02:23.733 to make it easier for y'all and for us at the same time. 00:02:24.830 --> 00:02:26.780 Another item is make sure that you go through 00:02:26.780 --> 00:02:29.010 and know that whenever we go through and do one of these, 00:02:29.010 --> 00:02:33.210 we're gonna be looking at both Texas Administrative Code, 00:02:33.210 --> 00:02:34.560 which is the state code, 00:02:34.560 --> 00:02:39.470 and 49 CFR or Code of Federal Regulations, 00:02:39.470 --> 00:02:42.230 which is basically the federal or PHMSA code 00:02:42.230 --> 00:02:44.650 at the same time when we're doing 00:02:44.650 --> 00:02:46.400 an inspection on one of your programs. 00:02:46.400 --> 00:02:49.513 So do be aware that we will be asking questions about both. 00:02:50.580 --> 00:02:53.040 Also, we do have someone that is going through 00:02:53.040 --> 00:02:55.280 and manning the questions 00:02:55.280 --> 00:02:58.280 in the question and answers section of the presentation, 00:02:58.280 --> 00:03:00.040 so feel free to ask your questions 00:03:00.040 --> 00:03:01.390 throughout the presentation, 00:03:01.390 --> 00:03:04.460 and we'll do the best that we can to get you an answer there 00:03:04.460 --> 00:03:06.280 when you've asked it. 00:03:06.280 --> 00:03:08.520 If there happens to be one that we cannot, 00:03:08.520 --> 00:03:10.300 we will go through and do our best to get you an answer 00:03:10.300 --> 00:03:12.303 as quickly as we can afterwards. 00:03:14.230 --> 00:03:16.700 So, to get started, we're going to go through 00:03:16.700 --> 00:03:19.370 and have Mr. Ross Richardson go first, 00:03:19.370 --> 00:03:21.040 who's gonna be talking about new construction. 00:03:21.040 --> 00:03:22.590 So Ross, whenever you're ready. 00:03:23.720 --> 00:03:25.340 Thank you, Michael. 00:03:25.340 --> 00:03:27.620 Hello everyone, good morning. 00:03:27.620 --> 00:03:29.190 My name is Ross Richardson. 00:03:29.190 --> 00:03:32.620 I am the new construction lead for the state of Texas, 00:03:32.620 --> 00:03:34.070 Pipeline and Safety division. 00:03:35.540 --> 00:03:37.770 When we're talking about construction, 00:03:37.770 --> 00:03:39.614 new constructional pipelines, 00:03:39.614 --> 00:03:41.630 what are we talking about? 00:03:41.630 --> 00:03:45.890 Well, this can be new pipeline systems, 00:03:45.890 --> 00:03:48.970 extension of an existing pipeline system, 00:03:48.970 --> 00:03:51.630 relocation of an existing pipeline system 00:03:51.630 --> 00:03:53.153 or a placement of a pipeline. 00:03:55.640 --> 00:03:58.570 So why is new construction important? 00:03:58.570 --> 00:04:00.490 New construction is our top priority 00:04:00.490 --> 00:04:02.003 here in Pipeline Safety. 00:04:03.350 --> 00:04:04.870 And the reason being is, 00:04:04.870 --> 00:04:07.770 it all starts with the construction of a pipeline. 00:04:07.770 --> 00:04:10.400 If you construct a pipeline safely, 00:04:10.400 --> 00:04:12.140 you get out on the right foot. 00:04:12.140 --> 00:04:14.560 So, it all starts with construction 00:04:14.560 --> 00:04:16.253 and it is a top priority. 00:04:18.530 --> 00:04:22.380 So, how does the Railroad Commission track new construction? 00:04:22.380 --> 00:04:25.810 We utilize what is called a PS-48 form. 00:04:25.810 --> 00:04:28.450 That form is filled out by the operator 00:04:28.450 --> 00:04:32.210 and it basically states what the project is, 00:04:32.210 --> 00:04:35.830 what it will involve, where it's located, 00:04:35.830 --> 00:04:38.200 and that type of information. 00:04:38.200 --> 00:04:41.310 PS-48 forms can be found here at this link, 00:04:41.310 --> 00:04:44.403 which is on the RRC website. 00:04:46.940 --> 00:04:49.520 So, what rules regulate 00:04:49.520 --> 00:04:53.493 the reporting of a new pipeline project construction? 00:04:54.700 --> 00:04:56.810 You have your federal codes, 00:04:56.810 --> 00:05:02.740 that will be 49 CFR 191.22, for gas pipelines. 00:05:02.740 --> 00:05:06.721 And then you have, 49 CFR 195.64, 00:05:06.721 --> 00:05:08.317 and that would be for liquid pipelines. 00:05:08.317 --> 00:05:12.810 And then you also have Texas Administrative Code 8.115, 00:05:12.810 --> 00:05:15.890 which is a general for all regulated 00:05:15.890 --> 00:05:18.620 jurisdictional pipelines within the state. 00:05:18.620 --> 00:05:20.910 And then also for H2S pipelines, 00:05:20.910 --> 00:05:25.767 you have Texas Administrative Code 3.36 and 3.106. 00:05:30.430 --> 00:05:32.140 So when we come out and do 00:05:32.140 --> 00:05:35.060 a typical new construction inspection, 00:05:35.060 --> 00:05:36.640 what is involved? 00:05:36.640 --> 00:05:40.030 Well, your first step is going to be your pre-inspection. 00:05:40.030 --> 00:05:44.010 This is when, I, the inspector, or other inspectors, 00:05:44.010 --> 00:05:46.270 reach out to the operator 00:05:46.270 --> 00:05:51.200 and get an explanation of the scope of project 00:05:51.200 --> 00:05:53.590 to help better schedule for that week of inspection 00:05:53.590 --> 00:05:55.163 and/or weeks of inspection. 00:05:56.050 --> 00:06:00.343 This will involve, like I said, the scheduling, the scope, 00:06:02.240 --> 00:06:07.020 notify the operator what is expected during this inspection 00:06:07.020 --> 00:06:09.030 and that type of information. 00:06:09.030 --> 00:06:12.610 The second step, is gonna be procedures and records review 00:06:12.610 --> 00:06:14.350 and the details of the project, 00:06:14.350 --> 00:06:18.793 on-site and/or recently virtually, due to COVID, 00:06:20.160 --> 00:06:23.160 the review of those records and procedures virtually as well 00:06:23.160 --> 00:06:24.313 can be conducted. 00:06:25.330 --> 00:06:28.510 And this covers, like I said, all the details, 00:06:28.510 --> 00:06:31.820 procedures, records, all that information. 00:06:31.820 --> 00:06:34.573 And then the third would be the field inspection. 00:06:35.560 --> 00:06:38.000 This would be our, the inspector, myself, 00:06:38.000 --> 00:06:39.380 will go out to the field 00:06:39.380 --> 00:06:43.400 and conduct the visual field inspection portion 00:06:43.400 --> 00:06:45.890 of the pipeline that's either being constructed 00:06:45.890 --> 00:06:48.110 or has been completed, 00:06:48.110 --> 00:06:50.420 you know, the construction is completed. 00:06:50.420 --> 00:06:53.670 And then fourth, will be the closing and the findings. 00:06:53.670 --> 00:06:57.420 And there will be a closing at each week of inspection 00:06:57.420 --> 00:06:59.170 or each inspection closing 00:07:00.426 --> 00:07:03.870 to notify you of alleged violations of findings, 00:07:03.870 --> 00:07:05.133 that type of information. 00:07:08.010 --> 00:07:10.680 So why do we conduct new construction inspections 00:07:10.680 --> 00:07:13.030 with the Railroad Commission of Texas? 00:07:13.030 --> 00:07:15.120 Number one, is public safety. 00:07:15.120 --> 00:07:17.940 We conduct these to keep the public safe 00:07:17.940 --> 00:07:21.993 and to also keep the environment safe and property safe. 00:07:24.750 --> 00:07:26.810 And here's my contact information. 00:07:26.810 --> 00:07:30.620 If you have any questions now or moving forward, 00:07:30.620 --> 00:07:32.950 again, I am the new construction lead. 00:07:32.950 --> 00:07:37.740 My cell phone number there, 512-436-5308, 00:07:37.740 --> 00:07:39.480 give me a call anytime. 00:07:39.480 --> 00:07:41.690 And then of course, my email address, 00:07:41.690 --> 00:07:46.280 and that's ross.richardson@rrc.Texas.gov. 00:07:46.280 --> 00:07:47.480 Thank you for your time. 00:07:49.748 --> 00:07:52.150 All right. Thank you, Ross. 00:07:52.150 --> 00:07:55.230 So next up we have Mr. Jose Cheverez 00:07:55.230 --> 00:07:57.650 or as he likes to go through and be called, Chevy. 00:07:57.650 --> 00:07:58.580 And he's gonna be talking about 00:07:58.580 --> 00:07:59.960 operations and maintenance. 00:07:59.960 --> 00:08:02.310 So Chevy, whenever you're ready to get started. 00:08:03.873 --> 00:08:05.033 Good morning, everybody. 00:08:05.033 --> 00:08:08.180 Like Michael said, I usually go by Chevy. 00:08:08.180 --> 00:08:11.783 So if you'd call me, I'll answer Chevy, 00:08:12.960 --> 00:08:16.520 pretty much the entire Railroad Commission knows me as Chevy 00:08:16.520 --> 00:08:17.540 and a lot of operators. 00:08:17.540 --> 00:08:21.393 So, everyone knows about that nickname. 00:08:22.260 --> 00:08:25.180 So today we're gonna cover the inspection format, 00:08:25.180 --> 00:08:27.840 how we do our O&M inspections, 00:08:27.840 --> 00:08:30.740 the documents and records that we're gonna look at 00:08:30.740 --> 00:08:34.410 as well as any common concerns that we have in Texas 00:08:34.410 --> 00:08:36.313 for each pipeline system type. 00:08:37.280 --> 00:08:38.113 Next slide. 00:08:40.590 --> 00:08:44.480 So the inspection format is like Michael said earlier, 00:08:44.480 --> 00:08:46.600 we're gonna start with the opening meeting, 00:08:46.600 --> 00:08:50.130 we're gonna determine how many operator IDs 00:08:50.130 --> 00:08:53.140 or company IDs are covered under that inspection, 00:08:53.140 --> 00:08:55.610 to make sure we have the entire scope. 00:08:55.610 --> 00:08:58.600 And how your O&M is broken apart, 00:08:58.600 --> 00:09:02.880 and whether it's all encompassing or not, 00:09:02.880 --> 00:09:04.920 and what sections there are. 00:09:04.920 --> 00:09:08.400 Then we'll do the procedural review of all the procedures, 00:09:08.400 --> 00:09:10.350 which we'll talk about more. 00:09:10.350 --> 00:09:13.130 The documents or records, we'll talk about more. 00:09:13.130 --> 00:09:15.690 And then we'll have that same closing meeting 00:09:15.690 --> 00:09:18.120 where we'll cover all the goods, the bads, 00:09:18.120 --> 00:09:21.870 the notes, the findings, and the alleged violations. 00:09:21.870 --> 00:09:22.703 Next slide. 00:09:24.470 --> 00:09:26.930 So the inspection forms we use for O&M's 00:09:26.930 --> 00:09:31.570 can be provided by the inspector prior to the inspection. 00:09:31.570 --> 00:09:33.740 We use three Railroad Commission forms, 00:09:33.740 --> 00:09:38.740 we've adopted forms 8.1, 8.2, and 8.3, 00:09:39.340 --> 00:09:42.470 specifically for each type, transmission, distribution, 00:09:42.470 --> 00:09:44.930 and hazardous liquids, respectively. 00:09:44.930 --> 00:09:46.940 And then for an LNG facility, 00:09:46.940 --> 00:09:50.490 we still use the PHMSA form since Texas does not add any, 00:09:50.490 --> 00:09:52.160 or at least Pipeline Safety 00:09:52.160 --> 00:09:55.980 does not add any additional regulations for LNG. 00:09:55.980 --> 00:09:56.813 Next slide. 00:09:58.310 --> 00:10:00.330 So, once we start on that O&M, 00:10:00.330 --> 00:10:03.280 we're gonna go through the entire O&M 00:10:03.280 --> 00:10:07.963 from start to finish, page one to page 999. 00:10:08.860 --> 00:10:10.740 We're gonna go through every single procedure 00:10:10.740 --> 00:10:13.377 and look for the compliance with the federal code 00:10:13.377 --> 00:10:15.313 and the minimum expectations. 00:10:16.650 --> 00:10:19.620 That's going to include any local or regional 00:10:19.620 --> 00:10:22.620 standard operating procedures that you have, 00:10:22.620 --> 00:10:27.050 if they're specific to an area or to a specific pipeline. 00:10:27.050 --> 00:10:29.070 So we'll need you to bring those along 00:10:29.070 --> 00:10:31.370 if you're gonna do an inspection, 00:10:31.370 --> 00:10:32.800 as well as the original 00:10:32.800 --> 00:10:35.270 equipment manufacturer specifications. 00:10:35.270 --> 00:10:36.490 These are part of the O&M 00:10:36.490 --> 00:10:39.690 because the manufacturer has specific requirements 00:10:39.690 --> 00:10:41.840 on how to maintain that equipment, 00:10:41.840 --> 00:10:43.270 and you'll have to follow those 00:10:43.270 --> 00:10:44.923 in order to stay in compliance. 00:10:46.140 --> 00:10:48.380 The standalone programs that we do exclude 00:10:48.380 --> 00:10:50.680 are basically the other inspections 00:10:50.680 --> 00:10:53.020 that we're gonna cover today. 00:10:53.020 --> 00:10:57.497 Like Ross before, new construction is a separate inspection. 00:10:57.497 --> 00:10:59.690 And the other inspectors that'll follow me, 00:10:59.690 --> 00:11:01.170 the leads that'll follow me, 00:11:01.170 --> 00:11:04.360 those programs are standalone inspections. 00:11:04.360 --> 00:11:07.000 And so, we won't cover those during the O&M. 00:11:07.000 --> 00:11:08.670 We may have a little overlap 00:11:08.670 --> 00:11:10.560 just because of the way the rule is covered, 00:11:10.560 --> 00:11:12.700 but we're gonna try to stick to the O&M 00:11:12.700 --> 00:11:13.963 as much as possible. 00:11:15.720 --> 00:11:19.070 So this is a short list of the reports, 00:11:19.070 --> 00:11:22.530 records, and details we're gonna look at during an O&M. 00:11:22.530 --> 00:11:25.490 If you notice, this is a lot of the high level stuff, 00:11:25.490 --> 00:11:28.950 that's gonna be applicable to the entire O&M 00:11:28.950 --> 00:11:30.900 or to the company as a whole, 00:11:30.900 --> 00:11:32.880 or to an entire pipeline system, 00:11:32.880 --> 00:11:35.930 not just a single segment or region. 00:11:35.930 --> 00:11:38.710 We're trying to cover what the company is doing 00:11:38.710 --> 00:11:40.550 at the high level, 00:11:40.550 --> 00:11:42.610 because once we know the procedures and policies 00:11:42.610 --> 00:11:45.710 are accurate and effective at that level, 00:11:45.710 --> 00:11:49.630 then we get into the standard comprehensive inspections 00:11:49.630 --> 00:11:53.370 to make sure that that's being followed. 00:11:53.370 --> 00:11:55.950 And of course, the inspector always has the right 00:11:55.950 --> 00:11:58.090 to request additional documentation 00:11:58.090 --> 00:12:01.790 based off what he asked for prior to the inspection 00:12:01.790 --> 00:12:04.293 or anything he finds during the inspection. 00:12:06.980 --> 00:12:09.340 So, common concerns we've had. 00:12:09.340 --> 00:12:13.510 This data comes from the last two years 00:12:13.510 --> 00:12:16.620 since we didn't have the presentation last year. 00:12:16.620 --> 00:12:21.620 I've covered this from September 1st of fiscal year or 2019, 00:12:21.930 --> 00:12:23.563 all the way to July 1st. 00:12:24.520 --> 00:12:26.650 So for gas transmission companies, 00:12:26.650 --> 00:12:29.600 we had some issues with the O&M updates 00:12:29.600 --> 00:12:31.820 and the annual reporting. 00:12:31.820 --> 00:12:34.420 So the annual reporting is either not there 00:12:34.420 --> 00:12:37.660 or it's been late or it's inaccurate, 00:12:37.660 --> 00:12:40.540 it doesn't match your T4 miles. 00:12:40.540 --> 00:12:42.550 So your T4 regulated miles 00:12:42.550 --> 00:12:45.480 and your annual report Texas miles should match, 00:12:45.480 --> 00:12:48.240 because that's all of your regulated piping 00:12:49.330 --> 00:12:53.020 for both Texas and for the feds. 00:12:53.020 --> 00:12:54.490 And so those two numbers should match, 00:12:54.490 --> 00:12:56.630 and if they don't within a certain tolerance 00:12:56.630 --> 00:12:59.920 or you can't justify why those numbers don't match, 00:12:59.920 --> 00:13:02.240 that's where we have the concern. 00:13:02.240 --> 00:13:03.610 Same with the O&M updates, 00:13:03.610 --> 00:13:08.000 we've had a lot of rule changes in 2020 and 2021. 00:13:08.000 --> 00:13:10.950 And so, those rules need to get into the O&M 00:13:10.950 --> 00:13:14.933 by the effective dates or else you're not in compliance. 00:13:16.330 --> 00:13:18.530 For gas distribution, 00:13:18.530 --> 00:13:20.410 record keeping has become a problem, 00:13:20.410 --> 00:13:21.970 especially with the municipality 00:13:21.970 --> 00:13:24.633 or with private distribution operators. 00:13:25.810 --> 00:13:26.940 The rules are all there, 00:13:26.940 --> 00:13:29.360 we look at the O&M to meet compliance, 00:13:29.360 --> 00:13:31.170 but then you have to show compliance 00:13:31.170 --> 00:13:33.460 with all of those regulations as well. 00:13:33.460 --> 00:13:36.090 And so, the record keeping has to be sufficient, 00:13:36.090 --> 00:13:39.570 it has to be dated and written correctly, 00:13:39.570 --> 00:13:41.770 and it has to cover all the details 00:13:41.770 --> 00:13:44.403 to prove compliance with the regulations. 00:13:46.500 --> 00:13:48.300 We're not concerned with the clerical errors, 00:13:48.300 --> 00:13:50.300 we're concerned with things being missing, 00:13:50.300 --> 00:13:52.260 things being inaccurate, 00:13:52.260 --> 00:13:55.713 because the information is inaccurate, not because of typos. 00:13:57.000 --> 00:13:58.420 With municipalities, 00:13:58.420 --> 00:14:00.790 the leak complaints have become an issue, 00:14:00.790 --> 00:14:01.990 both in the procedures, 00:14:01.990 --> 00:14:05.800 as well as the 10:00 AM reviews by supervisors 00:14:05.800 --> 00:14:07.030 the next business day, 00:14:07.030 --> 00:14:09.040 they're just generally not there, 00:14:09.040 --> 00:14:11.520 either in the procedure or the record. 00:14:11.520 --> 00:14:13.300 So we're really cracking down on that 00:14:13.300 --> 00:14:14.993 to make sure it gets covered. 00:14:16.450 --> 00:14:18.780 For liquid operators, 00:14:18.780 --> 00:14:22.490 for the last two years, we're giving them a thumbs up. 00:14:22.490 --> 00:14:25.850 We've had over 100 inspections of liquid operators, 00:14:25.850 --> 00:14:29.900 and we have only had two violations repeated 00:14:29.900 --> 00:14:32.330 on two separate occasions, 00:14:32.330 --> 00:14:37.330 a P5 not being filed, either not being filed or delinquent, 00:14:37.520 --> 00:14:40.920 and then the emergency plan training and review 00:14:41.980 --> 00:14:46.040 was not either recorded or completed. 00:14:46.040 --> 00:14:49.100 So, we understand that COVID-19, 00:14:49.100 --> 00:14:52.460 and 2020 was a very difficult year, 00:14:52.460 --> 00:14:55.920 but those records still need to be in compliance. 00:14:55.920 --> 00:14:56.917 And they still need to be there, 00:14:56.917 --> 00:14:59.300 and the training still needs to be held. 00:14:59.300 --> 00:15:00.650 Other than that, 00:15:00.650 --> 00:15:05.650 we had nearly over 70 of the 115 liquid inspections 00:15:07.390 --> 00:15:09.710 that were done in those two years, 00:15:09.710 --> 00:15:11.770 did not have any violations. 00:15:11.770 --> 00:15:15.000 So, hazardous liquids, in general, 00:15:15.000 --> 00:15:17.693 have done very good in the last two years. 00:15:19.230 --> 00:15:24.230 And for O&Ms across the board, all of three types of O&M's, 00:15:24.860 --> 00:15:27.660 it's a general lack of specificity. 00:15:27.660 --> 00:15:29.920 The rules require you to stay in compliance. 00:15:29.920 --> 00:15:32.860 And a lot of the rules are written in a manner 00:15:32.860 --> 00:15:36.300 to allow the operator to make the decisions on their own. 00:15:36.300 --> 00:15:37.260 When it's written that way, 00:15:37.260 --> 00:15:40.230 you have to make those decisions and put them in writing. 00:15:40.230 --> 00:15:43.140 So every procedure should have a who, what, 00:15:43.140 --> 00:15:46.430 where, when, and how, for every single procedure, 00:15:46.430 --> 00:15:48.830 every single thing that you're doing. 00:15:48.830 --> 00:15:51.110 And some of those are given to you by the code, 00:15:51.110 --> 00:15:53.960 the rest have to be decided by the operator. 00:15:53.960 --> 00:15:55.420 So we need to see all of that 00:15:55.420 --> 00:15:57.523 in every single procedure we look at. 00:15:58.760 --> 00:15:59.593 Next slide. 00:16:01.420 --> 00:16:05.799 So, we covered how we do the O&M inspections, 00:16:05.799 --> 00:16:08.170 a short list of the documents and records 00:16:08.170 --> 00:16:10.540 that we use and what we look at, 00:16:10.540 --> 00:16:12.210 and the common concerns we've had 00:16:12.210 --> 00:16:13.663 in the last couple of years. 00:16:14.540 --> 00:16:16.610 If you download this presentation, 00:16:16.610 --> 00:16:18.360 there are some helpful links 00:16:18.360 --> 00:16:20.387 in the notes section of the slides 00:16:20.387 --> 00:16:24.590 that you can use to help prepare for an inspection. 00:16:24.590 --> 00:16:26.990 I've also included my contact information 00:16:26.990 --> 00:16:31.633 if you need to call or email me for any O&M questions, 00:16:31.633 --> 00:16:35.040 but that's all I've got for right now and today. 00:16:35.040 --> 00:16:35.873 Thank you. 00:16:37.230 --> 00:16:39.020 Thank you, Chevy, 00:16:39.020 --> 00:16:40.730 Up next, we have Mr. Blaine Jacobs, 00:16:40.730 --> 00:16:41.563 who's gonna be going through 00:16:41.563 --> 00:16:43.330 and talking about drug and alcohol. 00:16:43.330 --> 00:16:45.323 So, Blaine whenever you're ready sir. 00:16:46.400 --> 00:16:47.830 Yes, my name is Blaine Jacobs. 00:16:47.830 --> 00:16:49.970 I am the lead for the drug and alcohol 00:16:49.970 --> 00:16:51.533 specialized inspections. 00:16:56.000 --> 00:16:57.310 The agenda we'll be going over today 00:16:57.310 --> 00:16:58.720 are the agencies involved 00:16:58.720 --> 00:17:03.137 with the drug and alcohol programs, regulations, 00:17:03.137 --> 00:17:06.910 the inspection process, common inspection issues, 00:17:06.910 --> 00:17:10.483 and at the end, there'll be some informational websites. 00:17:12.940 --> 00:17:16.063 The agencies involved with the drug and alcohol, 00:17:16.900 --> 00:17:19.080 the main one is U.S Department of Transportation, 00:17:19.080 --> 00:17:21.140 they oversee the movement of everything 00:17:22.279 --> 00:17:25.610 in the United States as far as drug and alcohol. 00:17:25.610 --> 00:17:27.550 Under that, will be the Office of Drug & Alcohol 00:17:27.550 --> 00:17:29.520 Policy and Compliance. 00:17:29.520 --> 00:17:33.180 Basically, that is the entity that is responsible 00:17:33.180 --> 00:17:36.070 for publishing the rules and regulations, 00:17:36.070 --> 00:17:37.820 and they are the ones who interpret 00:17:39.047 --> 00:17:40.810 the rules and regulations. 00:17:40.810 --> 00:17:43.760 And then under that, there are various agencies 00:17:43.760 --> 00:17:46.380 that fall underneath that blanket, 00:17:46.380 --> 00:17:48.040 Office of Pipeline Safety, 00:17:48.040 --> 00:17:51.620 which is Pipeline Hazardous Material Safety Administration 00:17:51.620 --> 00:17:52.453 is one of them. 00:17:52.453 --> 00:17:55.340 You've also got Federal Motor Carrier, 00:17:55.340 --> 00:17:58.823 you have the U.S Coast Guard, you have 00:18:01.420 --> 00:18:02.450 Federal Aviation. 00:18:02.450 --> 00:18:04.830 Different ones that are involved in transportation, 00:18:04.830 --> 00:18:06.720 and each one is required to have 00:18:06.720 --> 00:18:10.550 a drug and alcohol plan and procedures, 00:18:10.550 --> 00:18:13.650 each one have their specific requirements. 00:18:13.650 --> 00:18:18.190 So you need to make sure that your plan is designed 00:18:18.190 --> 00:18:20.200 and meets the requirements for 00:18:20.200 --> 00:18:22.700 Pipeline Hazardous Material Safety Administration. 00:18:25.370 --> 00:18:28.020 The regulations that you're gonna be dealing with 00:18:28.020 --> 00:18:29.847 is gonna be 49 CFR 199 00:18:31.425 --> 00:18:34.340 and 49 CFR Part 40. 00:18:34.340 --> 00:18:37.514 199 basically tells what DOT 00:18:37.514 --> 00:18:40.130 and OPS require an operator to do 00:18:40.130 --> 00:18:42.253 as far as our policies and procedures. 00:18:43.314 --> 00:18:45.160 For now, CFR Part 40, 00:18:45.160 --> 00:18:47.900 addresses the parties who conduct testing 00:18:47.900 --> 00:18:49.683 and how the test will be conducted. 00:18:53.370 --> 00:18:55.460 Inspection process. 00:18:55.460 --> 00:18:56.850 The pre-inspection operator 00:18:56.850 --> 00:18:59.630 will be notified by the inspector. 00:18:59.630 --> 00:19:01.840 At that time, the operator can request a copy 00:19:01.840 --> 00:19:05.110 of the inspection form that we use, protocol form, 00:19:05.110 --> 00:19:06.840 so that you have an idea of what it is 00:19:06.840 --> 00:19:09.962 we're gonna be looking for during the inspection. 00:19:09.962 --> 00:19:12.510 The inspection itself will be a review of the plan 00:19:12.510 --> 00:19:14.570 and supporting documents. 00:19:14.570 --> 00:19:17.880 The inspection is designed 00:19:17.880 --> 00:19:22.333 or geared towards your designated employee representative, 00:19:23.660 --> 00:19:27.710 which is the person who manages your drug and alcohol plan. 00:19:27.710 --> 00:19:30.850 It's usually somebody, depending on the size of the company, 00:19:30.850 --> 00:19:33.183 is usually somebody in the HR department. 00:19:34.210 --> 00:19:37.090 Then possibly, be a collection site visit, 00:19:37.090 --> 00:19:40.740 depending on what's found in the initial part 00:19:40.740 --> 00:19:43.103 of the inspection process. 00:19:45.720 --> 00:19:50.190 Common issues that have been come across. 00:19:50.190 --> 00:19:52.670 Operator did not have a plan that met all the requirements 00:19:52.670 --> 00:19:56.583 of Parts 199 and Part 40. 00:19:57.990 --> 00:19:59.760 Then again, they must contain all the elements 00:19:59.760 --> 00:20:01.003 required by PHMSA. 00:20:02.910 --> 00:20:06.120 Basically, you've got 199 and Part 40, 00:20:06.120 --> 00:20:08.470 and both of those have to be, 00:20:08.470 --> 00:20:11.530 has specific issues or since specific items 00:20:11.530 --> 00:20:12.930 that need to be contained 00:20:12.930 --> 00:20:14.993 within your drug and alcohol plans. 00:20:17.550 --> 00:20:20.940 Another one is, no process to ensure contractors 00:20:20.940 --> 00:20:24.680 or service providers were compliant with regulations. 00:20:24.680 --> 00:20:29.680 As an operator, you've hired third-party contractors 00:20:29.930 --> 00:20:34.900 or third-party service providers to perform functions 00:20:34.900 --> 00:20:37.470 associated with your drug and alcohol plan. 00:20:37.470 --> 00:20:41.150 And you, as the operator, responsible for ensuring 00:20:41.150 --> 00:20:44.490 that those individuals are performing those tasks 00:20:44.490 --> 00:20:46.083 according to regulation. 00:20:47.915 --> 00:20:50.530 I99.115, the operator is responsible for 00:20:50.530 --> 00:20:53.080 contract compliance with regulations. 00:20:53.080 --> 00:20:56.760 And 40.11 and 40.15, is said that it is, 00:20:56.760 --> 00:20:58.140 where the operator's responsible 00:20:58.140 --> 00:21:01.003 for Service Agent compliance with regulations. 00:21:05.130 --> 00:21:06.540 Collection site monitoring. 00:21:06.540 --> 00:21:09.010 We run a across a lot of operators 00:21:09.010 --> 00:21:12.470 who have no documentation showing that they are 00:21:12.470 --> 00:21:15.493 making sure that the collection sites are in compliance. 00:21:16.530 --> 00:21:20.180 That's under 199.115 and 199.245, 00:21:21.850 --> 00:21:26.330 based on whether it's the drug side of it 00:21:26.330 --> 00:21:29.233 or the alcohol misuse prevention portion of the plan. 00:21:32.140 --> 00:21:35.080 Well, here's some informational websites that you can go to 00:21:35.080 --> 00:21:37.180 that have what... 00:21:38.020 --> 00:21:41.270 As specific information that as an employer 00:21:41.270 --> 00:21:43.320 or operator, you need to know, 00:21:43.320 --> 00:21:46.240 and answers any questions you might have as far as 00:21:46.240 --> 00:21:48.510 what needs to be in your plan, 00:21:48.510 --> 00:21:53.510 they also offer a pamphlet that PHMSA put out last year, 00:21:53.850 --> 00:21:57.843 they go step by step on how to inspect a collection site. 00:22:00.580 --> 00:22:03.020 Again, there's my contact information. 00:22:03.020 --> 00:22:04.700 If you have any questions, 00:22:04.700 --> 00:22:07.640 don't hesitate to reach out and get in touch with me. 00:22:07.640 --> 00:22:08.840 Thank you for your time. 00:22:10.320 --> 00:22:11.763 All right. Thank you, Blaine. 00:22:13.010 --> 00:22:16.220 Next up, we have public awareness and damage prevention, 00:22:16.220 --> 00:22:18.960 it's gonna be talked about by Mr. Pete Longoria. 00:22:18.960 --> 00:22:20.760 So whenever you're ready, sir. 00:22:20.760 --> 00:22:21.610 Okay. 00:22:21.610 --> 00:22:23.130 Good morning, my name is Pete Longoria, 00:22:23.130 --> 00:22:24.170 and I'm the team lead 00:22:24.170 --> 00:22:26.320 for public awareness and damage prevention. 00:22:27.610 --> 00:22:29.210 So a quick overview of everything 00:22:29.210 --> 00:22:30.330 that I'm gonna cover today. 00:22:30.330 --> 00:22:31.330 So we're gonna start with 00:22:31.330 --> 00:22:33.293 the importance of public awareness, 00:22:34.410 --> 00:22:37.100 then we're gonna move on to the regulations 00:22:37.100 --> 00:22:39.210 that govern public awareness, 00:22:39.210 --> 00:22:41.710 the public awareness and inspection process, 00:22:41.710 --> 00:22:44.480 some quick information on damage prevention, 00:22:44.480 --> 00:22:46.840 damage prevention regulations, 00:22:46.840 --> 00:22:49.350 the inspection process for damage prevention, 00:22:49.350 --> 00:22:51.360 common issues found during public awareness 00:22:51.360 --> 00:22:54.050 and damage prevention inspections, 00:22:54.050 --> 00:22:56.200 and then of course, my contact information. 00:22:57.860 --> 00:23:00.430 So, why is public awareness important? 00:23:00.430 --> 00:23:03.600 Well, we raise the awareness of presence of pipelines 00:23:03.600 --> 00:23:06.750 to the intended stakeholder audiences. 00:23:06.750 --> 00:23:11.020 And so, really the goal is to increase public understanding 00:23:11.020 --> 00:23:13.050 on the role of pipelines. 00:23:13.050 --> 00:23:16.360 So helping them understand that pipelines are the most, 00:23:16.360 --> 00:23:18.360 the safest and most reliable way 00:23:18.360 --> 00:23:21.780 to transport natural gas, crude, and refined product. 00:23:21.780 --> 00:23:25.690 And in turn, this also helps you as an operator, 00:23:25.690 --> 00:23:27.500 is promoting the safe operation of pipeline. 00:23:27.500 --> 00:23:29.960 So in the case of the public awareness, 00:23:29.960 --> 00:23:31.610 kind of getting ahead into damage prevention, 00:23:31.610 --> 00:23:33.920 but 811 is a big thing that we stress, 00:23:33.920 --> 00:23:35.070 calling before you dig. 00:23:36.000 --> 00:23:38.770 Letting the public know that there's a pipeline in the area, 00:23:38.770 --> 00:23:40.590 that can decrease your third-party strikes. 00:23:40.590 --> 00:23:43.560 And also, the information that you provide 00:23:43.560 --> 00:23:46.800 to the stakeholders has key information 00:23:46.800 --> 00:23:49.780 on how to identify potential leaks or hazards 00:23:49.780 --> 00:23:52.010 associated with pipeline releases, 00:23:52.010 --> 00:23:54.580 they could potentially have them 00:23:54.580 --> 00:23:56.830 notifying you before you have a bigger event. 00:23:59.290 --> 00:24:01.510 So, under federal regulation, 00:24:01.510 --> 00:24:04.370 each operator must establish a public awareness program. 00:24:04.370 --> 00:24:06.387 So there is a gas and the liquid requirement, 00:24:06.387 --> 00:24:10.200 so that is 49 CFR 192.616, for the gas, 00:24:10.200 --> 00:24:12.580 and 195.440 for liquid. 00:24:12.580 --> 00:24:17.580 In addition, API RP 1162 is incorporated by reference. 00:24:17.620 --> 00:24:21.170 This is where you as an operator find resources as far as 00:24:21.170 --> 00:24:23.530 how to identify your stakeholder audiences, 00:24:23.530 --> 00:24:25.320 how frequently you should be corresponding 00:24:25.320 --> 00:24:27.400 with these stakeholder audiences, 00:24:27.400 --> 00:24:31.050 and also, methods to evaluate your program 00:24:31.050 --> 00:24:33.913 and see whether or not the program is effective. 00:24:34.960 --> 00:24:37.480 Keeping in mind... Oops, sorry. 00:24:37.480 --> 00:24:39.070 So just real quick on the previous one, 00:24:39.070 --> 00:24:41.290 keep in mind that there are two additional, 00:24:41.290 --> 00:24:42.610 there are additional regulations 00:24:42.610 --> 00:24:44.360 in Texas Administrative Code 00:24:44.360 --> 00:24:47.130 for conducting liaison activities once per calendar year, 00:24:47.130 --> 00:24:51.323 not to exceed 15 months, and these are, TAC 8.235 00:24:52.779 --> 00:24:55.163 and TAC 8.310. 00:24:56.400 --> 00:24:59.210 So the inspection process for public awareness is, 00:24:59.210 --> 00:25:00.540 as everybody else mentioned, 00:25:00.540 --> 00:25:02.040 we wanna make sure that we're capturing 00:25:02.040 --> 00:25:06.200 any and all subsidiaries under that are covered by the plan. 00:25:06.200 --> 00:25:08.950 So, after we go ahead and verify that, 00:25:08.950 --> 00:25:11.150 we're gonna verify the miles of regulated pipeline. 00:25:11.150 --> 00:25:12.860 So, we're gonna break it down 00:25:12.860 --> 00:25:15.330 by gas gathering, gas transmission, 00:25:15.330 --> 00:25:17.230 liquid gathering, and liquid pipelines, 00:25:17.230 --> 00:25:19.710 and the miles associated with each. 00:25:19.710 --> 00:25:23.800 And after that, the main records portion is, 00:25:23.800 --> 00:25:26.120 identification of your stakeholder audiences, 00:25:26.120 --> 00:25:30.233 are you making the appropriate time, 00:25:32.430 --> 00:25:34.160 correspondents at the appropriate times 00:25:34.160 --> 00:25:35.770 to your stakeholder audiences? 00:25:35.770 --> 00:25:38.270 And then the biggest one is your annual reviews 00:25:38.270 --> 00:25:40.440 and your effectiveness evaluations 00:25:40.440 --> 00:25:42.740 to determine where it is that your program is. 00:25:47.760 --> 00:25:49.590 So, coming into damage prevention. 00:25:49.590 --> 00:25:51.570 So the leading cause of pipeline incidents 00:25:51.570 --> 00:25:53.090 is third-party damage. 00:25:53.090 --> 00:25:55.190 So the goal of damage prevention 00:25:55.190 --> 00:25:58.180 is to prevent damage to pipeline and its facilities. 00:25:58.180 --> 00:26:00.220 So again, as I mentioned before, 00:26:00.220 --> 00:26:03.360 public awareness damage prevention go hand in hand. 00:26:03.360 --> 00:26:04.710 You reach out to the public, 00:26:04.710 --> 00:26:08.000 you make them aware of the pipelines in the area, 00:26:08.000 --> 00:26:10.203 and we can help bring these numbers down. 00:26:11.110 --> 00:26:12.880 And so, just quick definition, 00:26:12.880 --> 00:26:16.320 excavation includes digging, trenching, blasting, 00:26:16.320 --> 00:26:17.453 and anything similar. 00:26:20.460 --> 00:26:22.060 So just like with public awareness, 00:26:22.060 --> 00:26:24.680 an operator must carry out a damage prevention program. 00:26:24.680 --> 00:26:27.487 So here you have 192.614 for gas, 00:26:27.487 --> 00:26:31.280 195.442 for liquid, And in addition to that, 00:26:31.280 --> 00:26:34.310 there is Texas Administrative Code Chapter 18, 00:26:34.310 --> 00:26:37.283 which has requirements for both excavators and operators. 00:26:40.320 --> 00:26:42.760 So just as with public awareness, 00:26:42.760 --> 00:26:47.350 we'll do a breakdown of mileage by commodity. 00:26:47.350 --> 00:26:48.670 And then in addition to that, 00:26:48.670 --> 00:26:50.610 the difference here is we're gonna look at, 00:26:50.610 --> 00:26:52.840 are you identifying your excavators? 00:26:52.840 --> 00:26:54.480 And we're gonna verify your one-call tickets. 00:26:54.480 --> 00:26:58.270 So, regulation requires you to keep them for five years. 00:26:58.270 --> 00:27:01.180 And in addition, we'll compare your numbers 00:27:01.180 --> 00:27:03.510 reported to PHMSA for third-party damage 00:27:03.510 --> 00:27:06.393 and your Texas damage reporting form submissions. 00:27:10.080 --> 00:27:12.760 So the most common issue, it's mainly with public awareness, 00:27:12.760 --> 00:27:15.270 and it's incomplete effectiveness evaluation. 00:27:15.270 --> 00:27:18.590 So the big three are either the effectiveness evaluations 00:27:18.590 --> 00:27:20.363 are exceeding the four-year mark, 00:27:21.620 --> 00:27:23.470 stakeholders aren't understanding 00:27:23.470 --> 00:27:25.530 the material being provided, 00:27:25.530 --> 00:27:28.740 and also, some operators are gathering the information, 00:27:28.740 --> 00:27:30.760 but they're not able to come up with a conclusion 00:27:30.760 --> 00:27:33.280 as to whether or not their program is effective. 00:27:33.280 --> 00:27:36.477 So those are the big three issues that we see. 00:27:41.070 --> 00:27:43.310 And so, here's my contact information. 00:27:43.310 --> 00:27:46.290 If you have any questions, feel free to reach out to me. 00:27:46.290 --> 00:27:47.123 Thank you. 00:27:48.770 --> 00:27:51.340 All right. Thank you, Pete. 00:27:51.340 --> 00:27:53.610 Up next, we have control room management 00:27:53.610 --> 00:27:55.360 and Mr. Mark Herrin is gonna go through 00:27:55.360 --> 00:27:57.080 and talk on that subject. 00:27:57.080 --> 00:27:58.720 And, whenever you're ready, sir. 00:27:58.720 --> 00:28:00.590 Right, good morning everybody. 00:28:00.590 --> 00:28:03.360 I'm the current control room management active lead, 00:28:03.360 --> 00:28:05.380 and here to talk about control room. 00:28:05.380 --> 00:28:08.820 So I pulled the definitions from the code. 00:28:08.820 --> 00:28:10.720 Control room, do you have a place and location 00:28:10.720 --> 00:28:13.270 for your controllers or personnel 00:28:13.270 --> 00:28:16.280 that's gonna be watching the SCADA system below? 00:28:16.280 --> 00:28:17.810 But you need a kind of computer based system 00:28:17.810 --> 00:28:19.950 that you get the information from your pipeline, 00:28:19.950 --> 00:28:24.090 pressures, anything of that nature into the control room. 00:28:24.090 --> 00:28:25.540 Go on the next slide, please. 00:28:26.840 --> 00:28:28.150 And then we have the controller, 00:28:28.150 --> 00:28:30.310 and they could define here by somebody that 00:28:30.310 --> 00:28:32.810 remotely monitors and controls the safety related operations 00:28:32.810 --> 00:28:35.590 of a pipeline facility with a SCADA system. 00:28:35.590 --> 00:28:38.120 So from this, we can see that, 00:28:38.120 --> 00:28:39.630 you know, control room is, 00:28:39.630 --> 00:28:41.820 you got a system, you see the information, 00:28:41.820 --> 00:28:44.490 and they can control it one way or the other. 00:28:44.490 --> 00:28:45.323 Next slide. 00:28:47.700 --> 00:28:51.230 And the FAQ A.07, which I have the link to the FAQ's 00:28:51.230 --> 00:28:52.480 at the end of this slide. 00:28:53.910 --> 00:28:55.430 This has a definition of, 00:28:55.430 --> 00:28:57.310 it helps you identify a controller. 00:28:57.310 --> 00:28:58.520 It's anybody that, 00:28:58.520 --> 00:29:00.130 whether you interact with the SCADA system 00:29:00.130 --> 00:29:01.230 to manipulate a valve 00:29:01.230 --> 00:29:03.920 or you call anybody else that can manipulate that valve 00:29:03.920 --> 00:29:04.820 or take care of an issue 00:29:04.820 --> 00:29:06.910 you see on a system or monitor. 00:29:06.910 --> 00:29:08.410 Those are controllers. 00:29:08.410 --> 00:29:09.243 Next slide. 00:29:10.820 --> 00:29:12.540 So, we'll talk about what to expect 00:29:12.540 --> 00:29:14.060 during the CRM inspection. 00:29:14.060 --> 00:29:17.630 So, generally we're going to determine 00:29:17.630 --> 00:29:20.770 what of your facilities are control rooms specifically. 00:29:20.770 --> 00:29:22.640 So, everything we're gonna talk about, 00:29:22.640 --> 00:29:24.470 we're gonna look at the process you use, 00:29:24.470 --> 00:29:26.170 procedures and documentation 00:29:26.170 --> 00:29:28.460 for everything throughout the process. 00:29:28.460 --> 00:29:29.293 Next slide. 00:29:31.640 --> 00:29:33.730 What is your effective data and control room plan 00:29:33.730 --> 00:29:34.960 and when was it implemented? 00:29:34.960 --> 00:29:36.640 The original date, original time 00:29:36.640 --> 00:29:38.300 when the control room was either active 00:29:38.300 --> 00:29:40.400 or the control room plan went into effect. 00:29:44.870 --> 00:29:46.890 Then we'll go into roles and responsibilities. 00:29:46.890 --> 00:29:48.550 What's the Controller Authority? 00:29:48.550 --> 00:29:49.383 Does he have authority 00:29:49.383 --> 00:29:51.380 to do everything he needs in his powers? 00:29:51.380 --> 00:29:53.220 Does that cover abnormal operations 00:29:53.220 --> 00:29:55.020 and emergency operations? 00:29:55.020 --> 00:29:56.790 What is his physical domain? 00:29:56.790 --> 00:29:58.570 Is it the one console that covers everything? 00:29:58.570 --> 00:30:01.840 Does that console only cover certain pipeline facilities? 00:30:01.840 --> 00:30:03.730 We'll talk about shift change. 00:30:03.730 --> 00:30:05.110 What are your procedures for that? 00:30:05.110 --> 00:30:06.343 How do you document it? 00:30:07.330 --> 00:30:09.340 We'll go through all of that good stuff. 00:30:09.340 --> 00:30:10.173 Next slide. 00:30:12.110 --> 00:30:14.870 All right, so do you give anyone to supersede 00:30:14.870 --> 00:30:16.790 or direct your controllers? 00:30:16.790 --> 00:30:18.760 So it's very important that you need to say, 00:30:18.760 --> 00:30:21.330 if they don't, nobody else can tell them what to do, 00:30:21.330 --> 00:30:22.270 need to put in your plan 00:30:22.270 --> 00:30:24.423 that it's either allowed or not allowed. 00:30:25.420 --> 00:30:26.520 How are they qualified 00:30:26.520 --> 00:30:28.800 if they are allowed to supersede them? 00:30:28.800 --> 00:30:32.730 And has there been any record events that's happened? 00:30:32.730 --> 00:30:33.563 Next. 00:30:35.570 --> 00:30:38.350 In your plan, you need to define what additions, expansions, 00:30:38.350 --> 00:30:40.640 or replacements are within your facilities. 00:30:40.640 --> 00:30:42.840 What are your procedures going to be for that? 00:30:42.840 --> 00:30:45.763 FAQ's C.15 and C.19 are good for that. 00:30:46.760 --> 00:30:48.290 All right, then next we're gonna look at 00:30:48.290 --> 00:30:50.280 your implementation of 1165. 00:30:50.280 --> 00:30:51.680 Procedures, documentation, 00:30:51.680 --> 00:30:54.400 talking about how your screens look, 00:30:54.400 --> 00:30:55.690 how all that stuff was implemented. 00:30:55.690 --> 00:30:57.230 Did you have a checklist? 00:30:57.230 --> 00:30:58.480 Or we just gonna look at it. 00:30:58.480 --> 00:30:59.313 Next slide. 00:31:01.790 --> 00:31:04.400 All right, safety related points. 00:31:04.400 --> 00:31:06.530 What is your process of going through those 00:31:06.530 --> 00:31:09.140 and making sure that everything that's safety related 00:31:09.140 --> 00:31:10.640 is in the SCADA system? 00:31:10.640 --> 00:31:11.570 What's the records of that? 00:31:11.570 --> 00:31:13.530 Do you have a master list? 00:31:13.530 --> 00:31:15.600 I have the point to point verification, 00:31:15.600 --> 00:31:17.080 going out there saying, 00:31:17.080 --> 00:31:19.250 all right, this communicates, it's working, 00:31:19.250 --> 00:31:21.040 they have accurate information. 00:31:21.040 --> 00:31:21.873 Next slide. 00:31:23.560 --> 00:31:25.660 What is your internal communication plan? 00:31:25.660 --> 00:31:26.920 Do you call everybody? 00:31:26.920 --> 00:31:28.500 What's your procedures and process? 00:31:28.500 --> 00:31:30.640 Do we call everybody, get their names? 00:31:30.640 --> 00:31:32.290 Make sure that the phone numbers are still good 00:31:32.290 --> 00:31:33.970 in an emergency. 00:31:33.970 --> 00:31:35.770 Do you have a backup SCADA system? 00:31:35.770 --> 00:31:38.110 So we need to find out if you have one, 00:31:38.110 --> 00:31:39.070 we'll take a look at it, 00:31:39.070 --> 00:31:41.130 if not, it's something we don't have to look at at all. 00:31:41.130 --> 00:31:44.663 So, the process of how you go out to it, check it, 00:31:45.720 --> 00:31:47.310 logistics of how to getting out there, 00:31:47.310 --> 00:31:49.840 what's your timeline and then the records of all that? 00:31:49.840 --> 00:31:50.673 Next slide. 00:31:55.420 --> 00:31:56.403 Fatigue management. 00:31:57.510 --> 00:31:59.340 Something that has been missed lately is, 00:31:59.340 --> 00:32:01.130 operator specific fatigue risks, 00:32:01.130 --> 00:32:01.963 it could be anything 00:32:01.963 --> 00:32:04.510 specific to your control room specifically, 00:32:04.510 --> 00:32:07.560 such as Downtown Houston traffic could cause an issue, 00:32:07.560 --> 00:32:09.240 you might've changed your start times 00:32:09.240 --> 00:32:11.670 for you controllers specifically. 00:32:11.670 --> 00:32:12.653 We'll talk about, 00:32:14.030 --> 00:32:17.000 did your controllers have any accidents or incidents 00:32:17.000 --> 00:32:18.510 and did fatigue play a role in that? 00:32:18.510 --> 00:32:20.280 How did you investigate that? 00:32:20.280 --> 00:32:22.060 If you did investigate that and found nothing, 00:32:22.060 --> 00:32:23.260 did you document it? 00:32:23.260 --> 00:32:24.450 If there was something that happened, 00:32:24.450 --> 00:32:26.190 how did you document that? 00:32:26.190 --> 00:32:28.010 Then you're gonna talk about, the shift lengths. 00:32:28.010 --> 00:32:29.160 How did you determine that? 00:32:29.160 --> 00:32:30.940 Is there, did you do a study? 00:32:30.940 --> 00:32:32.730 Did you use a pre-approved? 00:32:32.730 --> 00:32:34.810 Then we're gonna do fatigue training. 00:32:34.810 --> 00:32:36.570 What did you use? Presentations, 00:32:36.570 --> 00:32:38.830 how do you continue that training as well? 00:32:38.830 --> 00:32:39.663 Next slide. 00:32:41.810 --> 00:32:43.540 Go into the alarm management. 00:32:43.540 --> 00:32:45.330 So what is the philosophy that you use 00:32:45.330 --> 00:32:48.200 for your alarm management, rationalization? 00:32:48.200 --> 00:32:50.353 And then we're going to your safety related points 00:32:50.353 --> 00:32:51.660 that we looked at earlier. 00:32:51.660 --> 00:32:52.900 What are those set points? 00:32:52.900 --> 00:32:55.320 We'll go through and see what you got. 00:32:55.320 --> 00:32:56.720 Then you'll need to do your annual review 00:32:56.720 --> 00:32:58.410 of your alarm management plan, 00:32:58.410 --> 00:33:00.410 one year not to exceed 15 months. 00:33:00.410 --> 00:33:03.530 So, you can't have that 15 months and skip a year, 00:33:03.530 --> 00:33:04.980 you have to do it every year. 00:33:05.870 --> 00:33:06.703 Next slide. 00:33:08.610 --> 00:33:09.723 Monthly analysis. 00:33:10.600 --> 00:33:11.650 What you took off scan, 00:33:11.650 --> 00:33:13.830 did you inhibit any alarms, false alarms? 00:33:13.830 --> 00:33:15.730 Did you have any forced values? 00:33:15.730 --> 00:33:17.510 If so, how are you monitoring that? 00:33:17.510 --> 00:33:19.410 Are you making any corrections? 00:33:19.410 --> 00:33:21.820 Is there a timeline to get things fixed? 00:33:21.820 --> 00:33:24.550 And then, the timeline we're talking about promptly, 00:33:24.550 --> 00:33:28.850 that you define promptly fixing it as a week, a year, 00:33:28.850 --> 00:33:31.530 you might be a little long for a SCADA system point. 00:33:31.530 --> 00:33:32.783 So, next slide. 00:33:35.640 --> 00:33:36.750 Measuring your workload. 00:33:36.750 --> 00:33:38.070 How do you know workload studies, 00:33:38.070 --> 00:33:40.710 making sure that they're not overburdened 00:33:40.710 --> 00:33:41.817 or they can't get their work done 00:33:41.817 --> 00:33:44.520 and in case something happens? 00:33:44.520 --> 00:33:46.620 So, we'll look at the workload study you're doing, 00:33:46.620 --> 00:33:48.180 how did you measure the metrics, 00:33:48.180 --> 00:33:49.540 if the metrics make sense, 00:33:49.540 --> 00:33:52.150 and how many records do you have? 00:33:52.150 --> 00:33:54.320 Look at your alarm deficiency resolution. 00:33:54.320 --> 00:33:56.560 FAQ E.16 is very good for this 00:33:56.560 --> 00:33:57.890 to give you an idea of what to do 00:33:57.890 --> 00:34:00.080 if you don't already have an idea. 00:34:00.080 --> 00:34:00.913 Next slide. 00:34:02.750 --> 00:34:04.010 Change management. 00:34:04.010 --> 00:34:07.420 So, you're changing a valve out in the field 00:34:07.420 --> 00:34:10.330 to another location and that valve no longer exists. 00:34:10.330 --> 00:34:11.750 Did you inform the control room 00:34:11.750 --> 00:34:14.450 or have anybody from the control room participate 00:34:14.450 --> 00:34:16.620 in how that might affect the pipeline? 00:34:16.620 --> 00:34:20.000 So that's one of the change managements that we'll look at. 00:34:20.000 --> 00:34:20.950 Next slide, please. 00:34:22.960 --> 00:34:24.170 Lessons learned. 00:34:24.170 --> 00:34:27.230 So, did your company have any incidents or accidents 00:34:27.230 --> 00:34:28.950 or any, you know, near misses that 00:34:28.950 --> 00:34:31.580 you could take to the control room or anywhere 00:34:31.580 --> 00:34:33.600 and apply that as a lessons learned. 00:34:33.600 --> 00:34:35.280 If something outside the company happened 00:34:35.280 --> 00:34:37.890 that could potentially help your company. 00:34:37.890 --> 00:34:39.510 So, you would recommend 00:34:39.510 --> 00:34:42.120 adding any of that stuff you can find. 00:34:42.120 --> 00:34:42.953 Next slide. 00:34:44.720 --> 00:34:45.950 We're going to training. 00:34:45.950 --> 00:34:49.520 So, what are the qualifications to become a controller? 00:34:49.520 --> 00:34:52.112 And when do you determine them to be qualified? 00:34:52.112 --> 00:34:54.670 Because you can complete CBT's relatively quickly 00:34:54.670 --> 00:34:58.030 if you're using CBT's on the job training. 00:34:58.030 --> 00:34:59.290 You probably wouldn't have somebody 00:34:59.290 --> 00:35:01.230 two weeks into their training 00:35:01.230 --> 00:35:03.590 to start working on a controller. 00:35:03.590 --> 00:35:05.660 So when do you determine them to be qualified 00:35:05.660 --> 00:35:07.230 to run as a controller. 00:35:07.230 --> 00:35:08.070 And then you'll wanna review 00:35:08.070 --> 00:35:10.120 your current training program every year. 00:35:10.980 --> 00:35:11.813 Next slide. 00:35:13.180 --> 00:35:16.090 This one is relatively new, the control room team training. 00:35:16.090 --> 00:35:17.530 You need to identify 00:35:17.530 --> 00:35:20.600 who works with the control room personnel. 00:35:20.600 --> 00:35:23.030 So that's gonna be people in the field, 00:35:23.030 --> 00:35:26.170 that's gonna people who do anything out there, 00:35:26.170 --> 00:35:28.030 schedulers, 00:35:28.030 --> 00:35:31.090 do they talk to any other company controllers? 00:35:31.090 --> 00:35:32.740 You just need to talk to anybody within your company 00:35:32.740 --> 00:35:34.000 that you can get on that. 00:35:34.000 --> 00:35:35.210 And then what are your procedures 00:35:35.210 --> 00:35:37.490 for identifying those people? 00:35:37.490 --> 00:35:39.200 How do you get their training done? 00:35:39.200 --> 00:35:42.000 If you have new hires into the field, 00:35:42.000 --> 00:35:44.890 when do you establish they need to have this training done? 00:35:44.890 --> 00:35:47.340 We'll look at the documentation that you have. 00:35:47.340 --> 00:35:49.470 And then, FAQ's PHMSA put out, 00:35:49.470 --> 00:35:51.680 H.05 through H.09 is very helpful 00:35:51.680 --> 00:35:54.410 and I recommend going through those for this program. 00:35:54.410 --> 00:35:55.310 Next slide please. 00:35:57.280 --> 00:36:00.060 And here's the link to the FAQ's as I was talking about, 00:36:00.060 --> 00:36:01.980 this will bring you, I checked it today again, 00:36:01.980 --> 00:36:04.293 and this is still a good link. 00:36:06.020 --> 00:36:07.260 Recommend going through this, 00:36:07.260 --> 00:36:08.920 it's a little lengthy, 00:36:08.920 --> 00:36:10.870 but it's got great information for control rooms 00:36:10.870 --> 00:36:12.220 and control room operators. 00:36:13.640 --> 00:36:14.473 Next slide. 00:36:15.900 --> 00:36:18.250 And this is my contact information. 00:36:18.250 --> 00:36:20.400 Again, I'm the current control room lead. 00:36:20.400 --> 00:36:21.760 If you have any questions 00:36:21.760 --> 00:36:23.950 and you need some help or guidance, 00:36:23.950 --> 00:36:27.350 please contact me and we'll work through whatever you got. 00:36:27.350 --> 00:36:28.350 Thank you very much. 00:36:29.940 --> 00:36:31.780 All right. Thank you, Mark. 00:36:31.780 --> 00:36:33.790 Up next, for operator qualification, 00:36:33.790 --> 00:36:35.890 we have Mr. Derek Lawrence. 00:36:35.890 --> 00:36:37.390 So whenever you're ready, sir. 00:36:38.390 --> 00:36:39.440 Thank you, Michael. 00:36:40.580 --> 00:36:41.413 My name is Derek Lawrence, 00:36:41.413 --> 00:36:44.100 I am the OQ lead for the state of Texas. 00:36:44.100 --> 00:36:47.387 Today we'll be covering what to expect on an OQ inspection 00:36:47.387 --> 00:36:50.870 and as well as some of the code references for that. 00:36:52.340 --> 00:36:55.990 We starting with covered tasks and the definitions of that, 00:36:55.990 --> 00:36:57.320 OQ evaluations, 00:36:57.320 --> 00:36:58.780 then we'll go over record maintenance, 00:36:58.780 --> 00:36:59.613 program review, 00:36:59.613 --> 00:37:01.593 and then commonly cited violations. 00:37:03.300 --> 00:37:05.503 The covered task is, 00:37:08.370 --> 00:37:11.510 is a part of any task, that is, meets the four-part task, 00:37:11.510 --> 00:37:14.573 which is a requirement of state or federal code, 00:37:17.560 --> 00:37:20.930 an operation or maintenance task, and is... 00:37:24.290 --> 00:37:25.123 My apologies. 00:37:27.290 --> 00:37:28.720 Is performing a pipeline facility 00:37:28.720 --> 00:37:31.990 and is detrimental to the safety 00:37:31.990 --> 00:37:34.313 of the pipeline system itself. 00:37:37.160 --> 00:37:39.630 Just so you know, the Texas Administrative Code 00:37:39.630 --> 00:37:42.553 is applicable to the rule for the four-part task. 00:37:44.070 --> 00:37:45.380 One thing we've been seeing in the field 00:37:45.380 --> 00:37:47.970 is generic covered tasks, 00:37:47.970 --> 00:37:50.310 where we'll go through an operator's OQ plan, 00:37:50.310 --> 00:37:51.880 and we're noticing that, 00:37:51.880 --> 00:37:53.800 they all have a list of covered tasks 00:37:53.800 --> 00:37:56.500 that are applicable to the rule, 00:37:56.500 --> 00:37:58.290 but they're not using it all. 00:37:58.290 --> 00:38:00.760 So, one thing that might be helpful to you guys 00:38:00.760 --> 00:38:02.570 to know which tasks do you need is to go through, 00:38:02.570 --> 00:38:04.280 and when you're doing your review of your program, 00:38:04.280 --> 00:38:07.240 make sure that the tasks that are in your program 00:38:07.240 --> 00:38:09.970 are applicable to your pipeline that you're using. 00:38:09.970 --> 00:38:11.510 For example, if you have gas 00:38:11.510 --> 00:38:14.870 and you don't do any liquid pipelines, 00:38:14.870 --> 00:38:16.810 you probably don't need, 00:38:16.810 --> 00:38:19.820 you know, starting up a pump as a covered task, 00:38:19.820 --> 00:38:21.993 because that would be related to liquid lines. 00:38:26.610 --> 00:38:27.443 We're gonna start with 00:38:27.443 --> 00:38:29.530 what we're gonna look for in an OQ evaluation. 00:38:29.530 --> 00:38:32.890 This will come from the definitions page right now, 00:38:32.890 --> 00:38:36.780 and that's 192.803 and 192.503. 00:38:36.780 --> 00:38:39.000 Is for you to get our definition for AOC, 00:38:39.000 --> 00:38:41.190 which is an operators are asked to ensure that AOC, 00:38:41.190 --> 00:38:43.190 which is that abnormal operating conditions, 00:38:43.190 --> 00:38:45.420 are noted on their evaluations 00:38:45.420 --> 00:38:46.930 along with the appropriate responses 00:38:46.930 --> 00:38:49.740 to ensure that the responses are correct, 00:38:49.740 --> 00:38:51.250 basically, you need to make sure that 00:38:51.250 --> 00:38:53.550 someone who is qualified can perform the covered tasks 00:38:53.550 --> 00:38:55.317 and recognize and react to an AOC. 00:38:56.410 --> 00:39:00.410 The evaluation methods listed in code are several, 00:39:00.410 --> 00:39:02.390 and you can use written evaluation, 00:39:02.390 --> 00:39:05.160 oral evaluation, Work Performance History Review, 00:39:05.160 --> 00:39:08.010 observation during performance on the job, 00:39:08.010 --> 00:39:09.610 on-the-job training or simulations 00:39:09.610 --> 00:39:11.110 or another form of assessment. 00:39:15.462 --> 00:39:16.643 192.805 and 195.505, 00:39:19.400 --> 00:39:22.080 this is where you get the bulk of your OQ program from. 00:39:22.080 --> 00:39:24.560 You need to identify covered tasks, 00:39:24.560 --> 00:39:27.570 ensure through evaluation that individuals are qualified 00:39:27.570 --> 00:39:29.230 to perform covered tasks, 00:39:29.230 --> 00:39:32.010 that you have procedures for directing and observing 00:39:32.010 --> 00:39:36.250 non-qualified individuals under a span of control. 00:39:36.250 --> 00:39:38.610 This is only if you allow non-qualified individuals 00:39:38.610 --> 00:39:40.921 to perform covered tasks on your pipeline facility. 00:39:40.921 --> 00:39:44.560 If you're requiring only covered individuals 00:39:44.560 --> 00:39:46.060 to perform covered tasking, 00:39:46.060 --> 00:39:48.070 I wouldn't say you need to worry about direct and observe, 00:39:48.070 --> 00:39:50.280 but it's always helpful to have that procedure in there 00:39:50.280 --> 00:39:52.850 in case you have a new trainee coming on 00:39:52.850 --> 00:39:55.330 who would do the tasks, you need to make sure that you have 00:39:55.330 --> 00:39:57.030 your span of control setup 00:39:57.030 --> 00:39:59.840 which is the number of how many individuals 00:39:59.840 --> 00:40:04.840 a person who is qualified can observe performing said tasks. 00:40:06.330 --> 00:40:09.160 You need to be able to evaluate an individual's performance 00:40:09.160 --> 00:40:10.683 contributed to an incident. 00:40:12.420 --> 00:40:15.930 One thing we're seeing is that some operators are using 00:40:15.930 --> 00:40:19.030 suspension and disqualification interchangeably. 00:40:19.030 --> 00:40:21.060 We would highly recommend that you 00:40:21.060 --> 00:40:23.670 figure out what those terms are for your plan 00:40:23.670 --> 00:40:25.430 and use them where they belong, 00:40:25.430 --> 00:40:27.800 such as, do you suspend someone 00:40:27.800 --> 00:40:29.350 when there's an accident occurred 00:40:29.350 --> 00:40:30.830 and they were performing covered task 00:40:30.830 --> 00:40:34.460 until you have time to do the investigation 00:40:34.460 --> 00:40:35.570 to determine whether or not 00:40:35.570 --> 00:40:39.440 they contributed or caused that incident? 00:40:39.440 --> 00:40:42.150 Disqualification would be after you've determined, 00:40:42.150 --> 00:40:44.800 yes, they've been, you know, they contributed to that. 00:40:44.800 --> 00:40:46.740 Then you would be able to go back and say, 00:40:46.740 --> 00:40:48.720 you need to go back through your training. 00:40:48.720 --> 00:40:50.710 You need to be able to evaluate if 00:40:50.710 --> 00:40:52.550 individuals are no longer qualified 00:40:52.550 --> 00:40:53.520 to perform covered tasks. 00:40:53.520 --> 00:40:56.910 This could be from observing them perform the covered task, 00:40:56.910 --> 00:41:01.910 maybe they've had a long absence from that covered task, 00:41:01.940 --> 00:41:05.160 whether that's through sickness, injury, 00:41:05.160 --> 00:41:07.130 just it's not something that they've done 00:41:07.130 --> 00:41:08.300 in a couple of years, 00:41:08.300 --> 00:41:10.370 maybe they need to be re-evaluated. 00:41:10.370 --> 00:41:12.070 So you would wanna have procedures in place 00:41:12.070 --> 00:41:13.403 to look into that. 00:41:14.536 --> 00:41:16.180 You need to be able to communicate changes 00:41:16.180 --> 00:41:17.013 to your individuals, 00:41:17.013 --> 00:41:21.270 is that through meetings, emails, telephone calls, 00:41:21.270 --> 00:41:22.490 updates to your, you know, 00:41:22.490 --> 00:41:26.450 publishing updates of your manual to all of your employees. 00:41:26.450 --> 00:41:28.950 Ensuring that individuals have the necessary 00:41:28.950 --> 00:41:29.783 knowledge and skills. 00:41:29.783 --> 00:41:31.610 So, when they're qualified, 00:41:31.610 --> 00:41:33.210 it's important that they don't just have 00:41:33.210 --> 00:41:34.560 a theoretical knowledge, 00:41:34.560 --> 00:41:37.323 they have the ability to actually do the tasks. 00:41:38.180 --> 00:41:40.110 We've seen cases where some operators, 00:41:40.110 --> 00:41:41.360 they don't have a way 00:41:41.360 --> 00:41:46.210 that either they weren't doing any CBT's or test, 00:41:46.210 --> 00:41:49.420 there was no way for them to indicate 00:41:49.420 --> 00:41:52.020 whether that an individual had the knowledge 00:41:53.530 --> 00:41:56.097 or skill sometimes to perform a covered tasked. 00:41:57.180 --> 00:41:58.730 And you need to have procedures 00:41:58.730 --> 00:42:00.500 to update PHMSA and the Railroad Commission 00:42:00.500 --> 00:42:03.173 of significant changes to your program. 00:42:07.026 --> 00:42:09.410 Important to note that during evaluations, 00:42:09.410 --> 00:42:11.550 we are gonna be looking to make sure that you, 00:42:11.550 --> 00:42:13.790 you as an operator are not using observation 00:42:13.790 --> 00:42:18.140 of on-the-job performance as a sole method of evaluation. 00:42:18.140 --> 00:42:20.730 And same with Work Performance History Review, 00:42:20.730 --> 00:42:23.160 neither of these can be used as a sole method. 00:42:23.160 --> 00:42:24.790 And this was back in 2002 00:42:24.790 --> 00:42:26.270 for Work Performance History Review 00:42:26.270 --> 00:42:28.900 and on-the-job performance in 2004. 00:42:28.900 --> 00:42:32.060 So by now, these should not be used as sole methods, 00:42:32.060 --> 00:42:33.410 you can combine them with others, 00:42:33.410 --> 00:42:37.283 whether that's a written test, oral tests or the like. 00:42:39.750 --> 00:42:43.933 Records, records are covered by 192.807 and 195.507. 00:42:46.120 --> 00:42:48.540 These records need to be for your employees 00:42:48.540 --> 00:42:50.030 and for your contractors. 00:42:50.030 --> 00:42:53.190 Please have a method of obtaining contract records 00:42:53.190 --> 00:42:57.630 before we get to the inspection, having them available. 00:42:57.630 --> 00:42:59.580 You need to make sure for both employees 00:42:59.580 --> 00:43:02.140 and contractors that are qualified, 00:43:02.140 --> 00:43:03.380 that you have an identification 00:43:03.380 --> 00:43:05.200 of who the individual is in the record, 00:43:05.200 --> 00:43:06.950 the identification of the covered tasks 00:43:06.950 --> 00:43:08.420 that the individual can perform, 00:43:08.420 --> 00:43:10.330 the dates of the current qualifications 00:43:10.330 --> 00:43:12.853 and the method used to qualify the individual. 00:43:14.090 --> 00:43:16.070 We are seeing cases where some of this information 00:43:16.070 --> 00:43:17.460 is being left out. 00:43:17.460 --> 00:43:19.370 It's important that for the records to be complete, 00:43:19.370 --> 00:43:20.920 that you have those four things. 00:43:20.920 --> 00:43:23.590 Ensure that for both employees and contractors, 00:43:23.590 --> 00:43:26.590 that you are keeping records for five years 00:43:26.590 --> 00:43:28.613 after the last time that task, 00:43:30.330 --> 00:43:32.590 last time that person was qualified for the task, 00:43:32.590 --> 00:43:36.040 whether that be they've gotten re-qualified on a task. 00:43:36.040 --> 00:43:38.340 So you will need to hold the old record for five years, 00:43:38.340 --> 00:43:39.980 or maybe they've retired 00:43:39.980 --> 00:43:42.300 or have left the company for some other reason, 00:43:42.300 --> 00:43:44.940 or just maybe they were promoted to a task 00:43:44.940 --> 00:43:47.863 that no longer requires them to perform covered tasks. 00:43:49.617 --> 00:43:51.240 You need to keep those records for five years 00:43:51.240 --> 00:43:53.973 from the date they're no longer performing those tasks. 00:43:58.290 --> 00:44:00.350 For the program review, 00:44:00.350 --> 00:44:03.540 you can send them to safety@rrc.Texas.gov. 00:44:03.540 --> 00:44:05.510 This is anytime you make a significant change, 00:44:05.510 --> 00:44:07.460 or if you just wanna send it in, 00:44:07.460 --> 00:44:09.940 when you develop a new plan. 00:44:09.940 --> 00:44:11.150 I know sometimes we have operators 00:44:11.150 --> 00:44:12.710 who develop new plans periodically, 00:44:12.710 --> 00:44:14.287 they just decide, you know what? 00:44:14.287 --> 00:44:15.800 we're gonna scrap this and just start over. 00:44:15.800 --> 00:44:17.443 Send that in to safety@rrc.Texas.gov 00:44:17.443 --> 00:44:19.107 so that we can review it. 00:44:19.107 --> 00:44:20.930 And this will not count as an inspection, 00:44:20.930 --> 00:44:24.363 but is something that we do require that operators do. 00:44:25.530 --> 00:44:29.530 Also, please note that OQ and O&M manuals go hand in hand. 00:44:29.530 --> 00:44:33.000 So it is very important to make sure that your tasks 00:44:33.000 --> 00:44:35.050 that you have for in your O&M manual, 00:44:35.050 --> 00:44:36.340 cause they're operation and maintenance tasks 00:44:36.340 --> 00:44:38.250 which is part of the four-part task, 00:44:38.250 --> 00:44:40.133 that you have OQs for those tasks. 00:44:43.360 --> 00:44:45.210 Commonly cited violations that we're seeing, 00:44:45.210 --> 00:44:46.440 wanna make you guys aware of, 00:44:46.440 --> 00:44:49.150 you have a chance to look through your program, 00:44:49.150 --> 00:44:52.150 determine if you have some of these issues and fix them, 00:44:52.150 --> 00:44:54.330 is that operators are failing to notify 00:44:54.330 --> 00:44:56.970 the Commission of significant changes. 00:44:56.970 --> 00:44:59.810 So, a significant change is determined by you, the operator, 00:44:59.810 --> 00:45:02.110 it should be written in your procedures. 00:45:02.110 --> 00:45:04.830 When you meet that significant change 00:45:04.830 --> 00:45:06.600 based on something you've done to your manual, 00:45:06.600 --> 00:45:08.950 you need to go ahead and send it into the Commission 00:45:08.950 --> 00:45:10.280 and let us know. 00:45:10.280 --> 00:45:12.130 It is helpful if you tell us, 00:45:12.130 --> 00:45:14.210 maybe with the manual, when you send it in, 00:45:14.210 --> 00:45:16.080 what it is that the significant changes are, 00:45:16.080 --> 00:45:18.823 and it really helps us in reviewing your manual. 00:45:20.810 --> 00:45:22.610 We're also seeing that the operators are using 00:45:22.610 --> 00:45:24.940 Work Performance History Review 00:45:24.940 --> 00:45:27.220 as a sole method of evaluation. 00:45:27.220 --> 00:45:30.210 Just remember that that is no longer allowed, 00:45:30.210 --> 00:45:33.503 but it can be used in conjunction with another task. 00:45:34.780 --> 00:45:36.210 We're seeing that the operators 00:45:36.210 --> 00:45:40.890 are not following procedures as outlined in their OQ plan, 00:45:40.890 --> 00:45:44.700 meaning either as something like they're not, 00:45:44.700 --> 00:45:48.260 they may have an annual review written into their plan 00:45:48.260 --> 00:45:49.250 and they're not doing it. 00:45:49.250 --> 00:45:50.630 So if you have something when written in your plan, 00:45:50.630 --> 00:45:51.463 we follow it. 00:45:51.463 --> 00:45:53.820 But also, your individuals that are qualified, 00:45:53.820 --> 00:45:58.190 make sure that they are able to do the task steps 00:45:58.190 --> 00:45:59.813 as outlined per your OQ plan. 00:46:00.690 --> 00:46:01.523 Excuse me. 00:46:02.580 --> 00:46:05.134 We're also seeing operators not have procedures 00:46:05.134 --> 00:46:08.740 and/or records for contractors performing covered tasks. 00:46:08.740 --> 00:46:10.890 The operator is ultimately responsible 00:46:10.890 --> 00:46:12.950 for all work done by a contractor 00:46:12.950 --> 00:46:17.150 and is responsible for having their OQ records 00:46:17.150 --> 00:46:20.590 and procedures to allow those individuals to work, 00:46:20.590 --> 00:46:23.710 whether that is how you're going to 00:46:23.710 --> 00:46:24.770 bring them into your plan, 00:46:24.770 --> 00:46:26.060 are you gonna train them on your plan? 00:46:26.060 --> 00:46:28.940 Do they have their own plan? Have you reviewed that plan? 00:46:28.940 --> 00:46:30.560 These kinds of things need to be considered 00:46:30.560 --> 00:46:33.460 in your procedures when developing contract for personnel. 00:46:36.290 --> 00:46:38.880 In summary, we've covered today, covered tasks, 00:46:38.880 --> 00:46:42.143 OQ evaluations, record maintenance, and program review. 00:46:42.980 --> 00:46:45.740 Just remember that the covered task 00:46:45.740 --> 00:46:48.400 is something that meets the four-part tasks. 00:46:48.400 --> 00:46:52.357 That operators should develop a tasks list 00:46:53.950 --> 00:46:57.810 for their company and for the tasks that they are performing 00:46:57.810 --> 00:46:59.337 with the span of control. 00:46:59.337 --> 00:47:01.460 And the years of the evaluation is good 00:47:01.460 --> 00:47:05.310 for whether that's one, two, three, four, five, 00:47:05.310 --> 00:47:08.680 and it should be able to justify 00:47:08.680 --> 00:47:12.900 what the reasoning for those evaluation intervals 00:47:12.900 --> 00:47:14.410 based on difficulty 00:47:14.410 --> 00:47:18.523 or how often is performed and other items. 00:47:20.640 --> 00:47:22.170 I thank you so much for your time. 00:47:22.170 --> 00:47:24.090 My contact information is provided on the screen. 00:47:24.090 --> 00:47:25.240 Again, my name is Derek Lawrence, 00:47:25.240 --> 00:47:27.280 I am the OQ lead for the state of Texas. 00:47:27.280 --> 00:47:30.640 My number is 512-971-3067, 00:47:30.640 --> 00:47:35.180 and you can reach at derek.lawrence@rrc.Texas.gov. 00:47:35.180 --> 00:47:36.013 Thank you. 00:47:38.070 --> 00:47:39.393 Thank you, Derek. 00:47:40.940 --> 00:47:42.730 Up next, for talking about 00:47:42.730 --> 00:47:44.640 both gas and liquid integrity managements, 00:47:44.640 --> 00:47:46.243 we have Miss Jennifer Delacruz. 00:47:47.640 --> 00:47:48.473 Good morning, everyone. 00:47:48.473 --> 00:47:49.860 My name is Jennifer Delacruz. 00:47:49.860 --> 00:47:53.170 I'm the lead for liquid integrity, 00:47:53.170 --> 00:47:56.570 and Evon Boothe is actually the lead for gas. 00:47:56.570 --> 00:47:59.840 So just starting with the applicability for gas, 00:47:59.840 --> 00:48:01.750 this is gonna be any gas transmission pipeline 00:48:01.750 --> 00:48:03.770 that could affect an HCA. 00:48:03.770 --> 00:48:07.100 And for liquids, it's each hazardous liquid 00:48:07.100 --> 00:48:09.750 and carbon dioxide pipeline that could affect an HCA. 00:48:13.470 --> 00:48:15.500 And then, for the state regulations, 00:48:15.500 --> 00:48:17.870 this is gonna cover basically all other 00:48:17.870 --> 00:48:21.490 intrastate transmission pipelines not affecting HCAs, 00:48:21.490 --> 00:48:23.483 and this includes gas and liquids. 00:48:25.820 --> 00:48:28.730 Okay, so some common issues that we see in integrity, 00:48:28.730 --> 00:48:31.930 the main one's gonna be documentation or integrity. 00:48:31.930 --> 00:48:34.050 All decisions need to be, 00:48:34.050 --> 00:48:35.800 really everything you do related to integrity 00:48:35.800 --> 00:48:37.300 needs to be documented, 00:48:37.300 --> 00:48:40.400 and this will include decisions to not take an action. 00:48:40.400 --> 00:48:42.090 So just as an example, 00:48:42.090 --> 00:48:44.080 you conduct an EFRD analysis, 00:48:44.080 --> 00:48:45.680 and you conclude that you don't need 00:48:45.680 --> 00:48:48.000 to install any additional ones. 00:48:48.000 --> 00:48:50.293 That's totally fine, just document that, 00:48:51.170 --> 00:48:52.823 and the justification behind it. 00:48:54.400 --> 00:48:57.310 An HCA determination needs to be done by all operators. 00:48:57.310 --> 00:48:59.967 So even if you don't have any HCA, 00:48:59.967 --> 00:49:02.350 so you still need to complete this part 00:49:02.350 --> 00:49:05.253 of the integrity requirement, 00:49:06.530 --> 00:49:08.193 and document that as well. 00:49:09.330 --> 00:49:10.960 Please keep in mind that when you're responding 00:49:10.960 --> 00:49:13.270 to any alleged violations, 00:49:13.270 --> 00:49:15.750 keep them very concise and specific 00:49:15.750 --> 00:49:18.930 to what the violation was in reference to, 00:49:18.930 --> 00:49:23.543 and that way we can tell how you're correcting it. 00:49:27.050 --> 00:49:29.400 Okay, so to touch a little bit on 00:49:29.400 --> 00:49:31.620 Texas integrity management rules 00:49:31.620 --> 00:49:34.210 and some of the terms used. 00:49:34.210 --> 00:49:38.390 They don't always line up with the federal regulations, 00:49:38.390 --> 00:49:41.270 so just risk-based and prescriptive. 00:49:41.270 --> 00:49:45.880 For Texas rules, you have to select whether you're gonna be 00:49:45.880 --> 00:49:48.270 risk-based or prescriptive per segment, 00:49:48.270 --> 00:49:49.490 that can change so you can have 00:49:49.490 --> 00:49:51.470 some risk-based, some prescriptive. 00:49:51.470 --> 00:49:53.320 When we're talking about risk-based, 00:49:53.320 --> 00:49:55.510 we mean based on a risk model. 00:49:55.510 --> 00:49:59.020 And then for prescriptive, it's a set interval 00:49:59.020 --> 00:50:01.453 based on figures 1 and 2 and TAC 8.101B2, 00:50:02.620 --> 00:50:06.550 and that's gonna be based on diameters, class, 00:50:06.550 --> 00:50:08.833 products and some other parameters as well. 00:50:09.740 --> 00:50:11.140 Please keep in mind direct assessment 00:50:11.140 --> 00:50:12.730 is only allowed for risk-based programs. 00:50:12.730 --> 00:50:14.270 So if you choose to be prescriptive, 00:50:14.270 --> 00:50:17.313 you cannot use ECDA as an integrity assessment method. 00:50:20.020 --> 00:50:21.590 Okay, so for the federal rules, 00:50:21.590 --> 00:50:24.083 again, this is only for could affect HCAs. 00:50:25.188 --> 00:50:27.540 And then again, with the terms here for gas, 00:50:27.540 --> 00:50:30.560 a prescriptive is really a simple risk plan. 00:50:30.560 --> 00:50:32.680 And then you've got performance, 00:50:32.680 --> 00:50:37.420 which is a robust risk plan based on 21 thread categories. 00:50:37.420 --> 00:50:38.360 And just FYI, 00:50:38.360 --> 00:50:43.360 I've never seen an operator use the performance method. 00:50:43.460 --> 00:50:46.010 For liquid, it's gonna be a risk model. 00:50:46.010 --> 00:50:48.470 And again, if it's an non-HCA pipeline, 00:50:48.470 --> 00:50:50.343 you'll follow Texas rules. 00:50:54.470 --> 00:50:57.480 Okay, so for gathering under the gas rule, 00:50:57.480 --> 00:50:59.490 they are exempt from integrity, 00:50:59.490 --> 00:51:01.413 but do expect an inspection. 00:51:03.150 --> 00:51:04.920 Just that we might conduct one 00:51:04.920 --> 00:51:08.690 just to verify that the determination was made properly 00:51:08.690 --> 00:51:11.980 and the documentation of how you came to that conclusion. 00:51:11.980 --> 00:51:14.620 And then for liquids, really the only exemption 00:51:14.620 --> 00:51:17.843 is for Category 3 low stress pipeline in a rural area. 00:51:22.280 --> 00:51:25.170 There was a new liquid rule 00:51:25.170 --> 00:51:28.342 that became effective July 1st, 2020, 00:51:28.342 --> 00:51:29.410 and this is for assessments 00:51:29.410 --> 00:51:32.150 for certain underwater facilities in HCAs. 00:51:32.150 --> 00:51:34.630 There's a whole paragraph there in 454 00:51:35.550 --> 00:51:38.830 that describes the whole applicability there, 00:51:38.830 --> 00:51:43.400 but really, it's facilities that are greater than 150 feet, 00:51:43.400 --> 00:51:44.760 under the surface of the water, 00:51:44.760 --> 00:51:48.160 and you'll need to do an ILI every 12 months, 00:51:48.160 --> 00:51:51.490 and any other pipeline integrity assessment 00:51:51.490 --> 00:51:53.170 completed on a schedule based on risks. 00:51:53.170 --> 00:51:55.070 So you would have to do both of these. 00:51:57.900 --> 00:52:01.190 And here's mine and Evon's contact information, 00:52:01.190 --> 00:52:03.730 please feel free to reach out with any questions. 00:52:03.730 --> 00:52:04.563 Thank you. 00:52:08.062 --> 00:52:09.733 All right. Thank you, Jennifer. 00:52:10.600 --> 00:52:13.600 Up next, for distribution integrity management, 00:52:13.600 --> 00:52:14.980 since we consider those to be separate, 00:52:14.980 --> 00:52:16.053 Mr. Isaac Monrreal. 00:52:17.710 --> 00:52:18.610 Thank you, Michael. 00:52:18.610 --> 00:52:19.617 My name is Isaac Monrreal, 00:52:19.617 --> 00:52:23.033 I'm the lead for the distribution integrity management, 00:52:24.880 --> 00:52:26.780 what we most affectionately call DIMP. 00:52:27.660 --> 00:52:30.430 Just kind of briefly go through a lot of this, 00:52:30.430 --> 00:52:32.490 we do have a new DIMP form 00:52:32.490 --> 00:52:34.990 that we are updating periodically. 00:52:34.990 --> 00:52:39.800 So, whenever you get a phone call to, 00:52:39.800 --> 00:52:42.670 for an inspector to come out and conduct an inspection, 00:52:42.670 --> 00:52:45.543 please ask them for the new DIMP forms. 00:52:46.410 --> 00:52:49.380 That is a combination of both state and federal codes, 00:52:49.380 --> 00:52:54.020 including the TAC 8.209. 00:52:54.020 --> 00:52:55.280 So when you do get that phone call, 00:52:55.280 --> 00:52:57.610 please be aware that please come prepared 00:52:57.610 --> 00:53:02.610 for all additional records and operating personnel, 00:53:02.640 --> 00:53:06.380 and most specifically, other manuals that you may have. 00:53:06.380 --> 00:53:10.587 Sometimes what we see is that you'll have your procedures 00:53:10.587 --> 00:53:12.980 in other manuals, 00:53:12.980 --> 00:53:14.760 such as your operation and maintenance manual 00:53:14.760 --> 00:53:18.770 for your leak complaints, leak management programs. 00:53:18.770 --> 00:53:20.760 So, just please come prepared with that, 00:53:20.760 --> 00:53:22.170 it kind of goes a long way 00:53:23.200 --> 00:53:25.840 for whenever we're conducting an inspection. 00:53:25.840 --> 00:53:27.750 One thing that I always like to highlight 00:53:27.750 --> 00:53:30.300 and talking about baseline 00:53:30.300 --> 00:53:31.420 and the difference between 00:53:31.420 --> 00:53:34.330 transmission and distribution integrity management. 00:53:34.330 --> 00:53:35.920 Specifically for distribution, 00:53:35.920 --> 00:53:38.740 we're really talking about baseline for performance measures 00:53:38.740 --> 00:53:40.140 and that's generalistically, 00:53:41.299 --> 00:53:44.650 basically, a year or a series of years 00:53:44.650 --> 00:53:46.453 that then an operator establishes 00:53:46.453 --> 00:53:49.480 for each mandatory performance measure 00:53:49.480 --> 00:53:52.650 under 192.1007 Part E. 00:53:52.650 --> 00:53:54.190 And then for those of y'all 00:53:54.190 --> 00:53:56.930 who are using the SHRIMP program, 00:53:56.930 --> 00:53:58.410 which is a Simple Handy Risk-based 00:53:58.410 --> 00:54:02.630 Integrity Management Program that PHMSA gave a grant for. 00:54:02.630 --> 00:54:04.610 The SHRIMP program does not do the baseline for you, 00:54:04.610 --> 00:54:05.810 it gives you a little bit of guidance, 00:54:05.810 --> 00:54:09.350 but it's that extra step that you have to do 00:54:09.350 --> 00:54:12.010 in order to meet compliance with the code. 00:54:12.010 --> 00:54:15.180 So, some of the common issues that we've been running into 00:54:15.180 --> 00:54:18.670 is again, kind of we're talking about for baseline 00:54:18.670 --> 00:54:21.820 is that you're not doing all of the five mandatory, 00:54:21.820 --> 00:54:24.210 the performance measures, that you're not documenting them, 00:54:24.210 --> 00:54:26.190 or you're not establishing them. 00:54:26.190 --> 00:54:29.150 Some other issues that we've run into quite frequently 00:54:29.150 --> 00:54:31.240 is for your periodic reviews, 00:54:31.240 --> 00:54:34.690 that they're either not done within the timeframe, 00:54:34.690 --> 00:54:36.440 under the slot which is five years. 00:54:37.520 --> 00:54:39.480 Or you're just not documenting that, 00:54:39.480 --> 00:54:41.580 what specifically did you actually review? 00:54:42.770 --> 00:54:46.950 And then in general, just a general lack of documentation. 00:54:46.950 --> 00:54:49.700 That's kind of like, kind of been like a recurring issue 00:54:49.700 --> 00:54:52.310 that we've kind of seen over and over and over again, 00:54:52.310 --> 00:54:54.230 not just with your DIMP program, 00:54:54.230 --> 00:54:59.230 but also as it applies to state code for the 8.209. 00:55:00.100 --> 00:55:04.080 So I just kinda want to emphasize just a little bit, 00:55:04.080 --> 00:55:05.690 you can go to the next slide please. 00:55:05.690 --> 00:55:07.880 And please, please, please document as much as you can, 00:55:07.880 --> 00:55:10.480 the DIMP program was intended to be a live document. 00:55:12.170 --> 00:55:14.860 We want you to be documenting legitimately 00:55:14.860 --> 00:55:17.430 every step, every action, every year. 00:55:17.430 --> 00:55:19.580 So then, also when we come and do an inspection, 00:55:19.580 --> 00:55:21.680 it just goes a lot smoother. 00:55:21.680 --> 00:55:24.690 So the last thing that I'll just want to put up on the slide 00:55:24.690 --> 00:55:25.828 is my contact information. 00:55:25.828 --> 00:55:29.420 If you have any questions, comments, or social observations, 00:55:29.420 --> 00:55:31.377 DIMP or GIMP related, feel free to reach out 00:55:31.377 --> 00:55:33.043 and I'll be more than happy to help out. 00:55:33.890 --> 00:55:35.090 Thank you for your time. 00:55:37.269 --> 00:55:38.940 All right. Thank you, Isaac. 00:55:38.940 --> 00:55:39.773 All right. 00:55:41.600 --> 00:55:43.650 Up next, for incidents and accidents, 00:55:43.650 --> 00:55:45.600 we have Mr. Godspower Oniovosa. 00:55:45.600 --> 00:55:47.910 So whenever you're ready, sir. 00:55:47.910 --> 00:55:49.040 Thank you, Michael. 00:55:49.040 --> 00:55:50.110 My name is Godspower Oniovosa, 00:55:50.110 --> 00:55:52.560 I'm the Accident/Incident investigation lead 00:55:52.560 --> 00:55:53.970 for the state of Texas. 00:55:53.970 --> 00:55:56.210 As we all know, accident and incident brings safety, 00:55:56.210 --> 00:55:59.260 kind of a shield into our body when we have them. 00:55:59.260 --> 00:56:02.551 But with the operations with your pipeline operators, 00:56:02.551 --> 00:56:03.850 there are safety requirements 00:56:03.850 --> 00:56:06.240 that whenever operator has accident or an incident 00:56:06.240 --> 00:56:08.270 on their pipelines, 00:56:08.270 --> 00:56:10.657 they must report to the Railroad Commission 00:56:10.657 --> 00:56:11.510 or the federal Commission. 00:56:11.510 --> 00:56:14.890 And there are safety requirements that are required, 00:56:14.890 --> 00:56:17.129 whenever there's an accident or incident 00:56:17.129 --> 00:56:18.155 happens on the pipelines. 00:56:18.155 --> 00:56:21.470 So for federal regulation that when an event 00:56:21.470 --> 00:56:25.095 involves the release of a gas on a pipeline 00:56:25.095 --> 00:56:26.000 or from a another gas facility 00:56:27.620 --> 00:56:30.100 of petroleum gas or refrigerant gas, 00:56:30.100 --> 00:56:32.977 pipeline operators are required to report 00:56:32.977 --> 00:56:36.970 under the federal regulation of 191.3, 00:56:36.970 --> 00:56:40.443 if that results into an event of a death or personal injury 00:56:40.443 --> 00:56:44.837 or installation on an estimated property damage of $122,000. 00:56:46.400 --> 00:56:49.510 Or if it involves only tensional release of the gas 00:56:49.510 --> 00:56:52.800 that is above of 3 million cubic or more, 00:56:52.800 --> 00:56:54.610 operators are required to report. 00:56:54.610 --> 00:56:57.470 And also likewise, if this event involves 00:56:57.470 --> 00:57:01.520 liquid or carbon dioxide or hazardous liquid 00:57:01.520 --> 00:57:04.330 from any of the pipelines, also (indistinct) storage, 00:57:05.466 --> 00:57:07.820 or involves the release of liquids, 00:57:07.820 --> 00:57:12.820 under the federal regulation of 195.5 and 195.52, 00:57:13.530 --> 00:57:17.600 pipeline operators must also report that accident 00:57:18.440 --> 00:57:21.990 to the federal, PHMSA, or to the Texas Railroad Commission. 00:57:21.990 --> 00:57:26.060 And if the events that involves the release of a liquid, 00:57:26.060 --> 00:57:29.913 if it involves the release of five gallons or, 00:57:32.664 --> 00:57:33.990 less the five barrels 00:57:33.990 --> 00:57:36.990 or involves death of a person or personal injury 00:57:36.990 --> 00:57:40.097 necessitating hospitalization, 00:57:40.097 --> 00:57:42.890 are also estimated property damage, 00:57:42.890 --> 00:57:44.520 involving cost of clean up 00:57:44.520 --> 00:57:47.120 and recovery of value of the product 00:57:47.120 --> 00:57:49.760 that is up to exceeding $50,000, 00:57:49.760 --> 00:57:53.980 they're also required to report that incident. 00:57:53.980 --> 00:57:56.810 Also on gathering lines, gas and liquid, 00:57:56.810 --> 00:57:58.210 this is to be regulated by 00:57:58.210 --> 00:58:00.610 the Texas Administrative Code (indistinct) 00:58:00.610 --> 00:58:02.610 under the regulated gathering lines. 00:58:02.610 --> 00:58:05.200 Whenever those releases are, you know, 00:58:05.200 --> 00:58:08.920 released from the gathering lines, either gas or liquid, 00:58:08.920 --> 00:58:13.490 the safety requirements by Texas Administrative Code 8.11, 00:58:13.490 --> 00:58:16.113 you're required to report those incidents. 00:58:19.701 --> 00:58:20.760 I wanna make some changes, 00:58:20.760 --> 00:58:23.030 there are some little changes that came up recently. 00:58:23.030 --> 00:58:25.537 On March 12th, I think this year, 2021, 00:58:25.537 --> 00:58:29.160 there was a change on one of the consequences 00:58:29.160 --> 00:58:31.280 under the regulation 191.3. 00:58:32.749 --> 00:58:35.620 Actually before, it was when the estimated property damage 00:58:35.620 --> 00:58:37.937 was like exceeding $50,000, 00:58:37.937 --> 00:58:40.793 but now, there are this changes, start operating in March, 00:58:40.793 --> 00:58:42.190 that whenever it exceeds, 00:58:42.190 --> 00:58:45.880 estimated property damage is $122,000. 00:58:45.880 --> 00:58:49.200 And this was as a result of adjustments before inflation, 00:58:49.200 --> 00:58:50.260 which was made to determine, 00:58:50.260 --> 00:58:55.240 and that determination is made in appendix A in Part 191. 00:58:55.240 --> 00:58:58.000 And I also want to also remind us, 00:58:58.000 --> 00:59:00.960 for liquid, there was no changes. 00:59:00.960 --> 00:59:05.340 The estimated property damage is still exceeding $50,000, 00:59:05.340 --> 00:59:10.010 but the difference is that it is inclusive of your products. 00:59:10.010 --> 00:59:12.500 Then also, another reminder is that, 00:59:12.500 --> 00:59:15.297 operators have to have in their O&M, 00:59:15.297 --> 00:59:18.790 accident and incident investigation procedure. 00:59:18.790 --> 00:59:21.410 This is for you to analyze the accident 00:59:21.410 --> 00:59:23.160 and also to determine the cause 00:59:23.160 --> 00:59:25.224 and to mitigate and minimize 00:59:25.224 --> 00:59:26.577 the possibility of the recurrence. 00:59:26.577 --> 00:59:29.180 And this are requirement per the federal code 00:59:29.180 --> 00:59:32.550 of 192.617 and for gas, 00:59:32.550 --> 00:59:37.550 and 195.402 A5-6 for liquid. 00:59:40.170 --> 00:59:42.390 And for Class 1 and rural gathering 00:59:42.390 --> 00:59:43.570 which I had mentioned earlier, 00:59:43.570 --> 00:59:46.210 that this is being regulated 00:59:46.210 --> 00:59:48.820 by Texas Administrative Code of 8.11. 00:59:48.820 --> 00:59:51.492 The reporting criteria we can find is about, 00:59:51.492 --> 00:59:52.343 for gas is 8.210A, 00:59:54.240 --> 00:59:56.050 and for liquid is 8.301A, 00:59:57.020 --> 00:59:59.110 which is stuff that you can find out 00:59:59.110 --> 01:00:02.002 on the release or whenever there's a release 01:00:02.002 --> 01:00:03.311 from Class 1 or rural gathering 01:00:03.311 --> 01:00:06.280 and the consequences that you must, as operator, 01:00:06.280 --> 01:00:08.440 must report to the Railroad Commission. 01:00:08.440 --> 01:00:10.413 And also about 8.110E, 01:00:11.354 --> 01:00:15.020 you're also required to perform an investigation requirement 01:00:15.020 --> 01:00:18.010 to analyze the accident to determine the cost 01:00:18.010 --> 01:00:20.393 and also to provide corrective action. 01:00:23.700 --> 01:00:25.950 So one of the (indistinct) expectations 01:00:25.950 --> 01:00:27.480 of the Railroad Commission is, 01:00:27.480 --> 01:00:29.510 one, whenever there's a release, 01:00:29.510 --> 01:00:31.910 whenever there's a reportable incident or accident, 01:00:31.910 --> 01:00:33.390 you are required by a procedure 01:00:33.390 --> 01:00:36.000 to analyze the accident and incidents 01:00:36.000 --> 01:00:37.590 to the time and the cost. 01:00:37.590 --> 01:00:39.620 And not just only the time and the cost, 01:00:39.620 --> 01:00:42.730 and also the plan to minimize reoccurence. 01:00:42.730 --> 01:00:44.290 These are also be determined 01:00:44.290 --> 01:00:45.900 that whenever with inspectors coming, 01:00:45.900 --> 01:00:48.070 when they're performing the accident investigation, 01:00:48.070 --> 01:00:50.620 you should be able to show documentation that this process, 01:00:50.620 --> 01:00:52.280 or these procedures are followed. 01:00:52.280 --> 01:00:53.860 And also, you also required to submit 01:00:53.860 --> 01:00:55.930 the 30-day report with applicable forms 01:00:55.930 --> 01:00:59.723 to the safety at Railroad Commission of Texas, .Texas.gov. 01:01:00.750 --> 01:01:02.050 I think if you will, 01:01:02.050 --> 01:01:04.100 for now if you have any information, 01:01:04.100 --> 01:01:06.060 as I told you, I'm the incident lead, 01:01:06.060 --> 01:01:07.815 and as (indistinct) all my contact information 01:01:07.815 --> 01:01:09.770 is (indistinct), Godspower Oniovosa, 01:01:09.770 --> 01:01:11.550 and my email and my phone contact. 01:01:11.550 --> 01:01:13.600 You can feel free to reach me, thank you. 01:01:14.510 --> 01:01:16.620 All right. Thank you Godspower. 01:01:16.620 --> 01:01:20.470 And that was all of our presenters that we had. 01:01:20.470 --> 01:01:21.440 Here on this slide, 01:01:21.440 --> 01:01:23.810 we go through and have the Commissioners listed out 01:01:23.810 --> 01:01:26.890 and a physical mail address, 01:01:26.890 --> 01:01:28.620 you can go through and reach out to them at, 01:01:28.620 --> 01:01:31.630 or any inquiries to anyone else in the Railroad Commission 01:01:31.630 --> 01:01:33.390 that you go through and have. 01:01:33.390 --> 01:01:35.580 We do want to go through and remind y'all 01:01:35.580 --> 01:01:37.010 that there is an evaluation 01:01:37.010 --> 01:01:39.490 that y'all can go through and take and complete 01:01:39.490 --> 01:01:40.840 at the following website. 01:01:40.840 --> 01:01:42.840 Again, if you download the copy of this presentation, 01:01:42.840 --> 01:01:45.360 you will have that link and be able to access it, 01:01:45.360 --> 01:01:47.770 go through and fill it out if you so choose to. 01:01:47.770 --> 01:01:49.470 And again, somewhere to the beginning, 01:01:49.470 --> 01:01:51.630 we're gonna be going through an archive in this video, 01:01:51.630 --> 01:01:54.220 and you can find it at the link that was provided, 01:01:54.220 --> 01:01:56.190 first, at the beginning of the presentation, 01:01:56.190 --> 01:01:59.710 and second, should be a link somewhere in the Q&A section 01:01:59.710 --> 01:02:00.980 to go through and list that out. 01:02:00.980 --> 01:02:03.420 So, thank you very much for going through and attending 01:02:03.420 --> 01:02:05.733 and I hope you have a wonderful rest of your day.