The Texas Railroad Commission (RRC) has broadened its Regulatory Focus to Include Rural Gathering Pipelines
H.B. 2982, recently signed into law by Gov. Rick Perry, authorizes the RRC to adopt and implement safety standards applicable to the intrastate transportation of hazardous liquids, carbon dioxide, and natural gas in rural locations by gathering pipelines. Rules implementing the legislation may be in place as early as the end of 2013. Previously, the RRC pipeline safety group did not regulate gathering pipelines in rural areas, imposing relatively few burdens on operators and producers. Rural gathering lines were considered non-jurisdictional under Texas law and were exempt from most safety regulations…that’s all about to change!
With the adoption of H.B. 2982, intrastate gathering pipelines in rural locations used to transport liquids, carbon dioxide and natural gas are now subject to RRC safety standards and regulations. The RRC now has the obligation to adopt and implement new rules that will apply to rural gathering pipelines. The RRC has always had jurisdiction over non-rural transportation and gathering pipelines. This new legislation also requires operators and producers who operate gathering pipelines to communicate and conduct liaison and public awareness activities with fire, police and other appropriate public emergency response officials, and One Call mapping and notices, just as operators of non-rural pipelines are already obligated to do.
Marabou Midstream Comment: This a huge change to the RRC’s jurisdictional role as it relates to natural gas gathering pipelines. Natural gas gathering systems in rural areas were previously exempt from RRC jurisdiction. With the passage of this legislation, however, no longer will pumpers, contract pumpers, gaugers, or occasional drive by patrols be considered legitimate operators of gathering pipelines. Soon, they must be properly trained, “Operator Qualified” (“OQ”) by trained evaluators of approved Training Proctors, and evaluated and tested for proper skills and procedures experience.
Marabou pipeline operations and maintenance personnel have been through the evaluations and have been successfully tested and qualified; further, to ensure continued compliance, and in all the states in which we operate pipelines for ourselves or others, we are also Qualified Evaluators of field personnel who must be OQ to be legitimate. We expect that the RRC rule changes associated with this legislation will also require operators to have written Safety Standards and Procedures Manuals, and Programs that must be evaluated and approved by the regulatory agency involved. Of course, there will be time to implement approved training of personnel and development of Safety and Procedure Programs and written Manuals, but make no mistake, in our opinion these new rules will be implemented in short order.
If you operate gathering pipelines in Texas you have, up until now, been under the radar and not subject to RRC jurisdiction. We feel strongly, however, that all of that is about to change, with new regulations and compliance requirements on the horizon. Marabou has your solution. Our personnel are trained and qualified, and we already operate pipelines in compliance with these anticipated regulations. Call or send us an email. We will assess your situation in light of these possible new rules and find the solution that works for you.
Marabou companies were founded with the mission of helping independent energy producers and end users get “closer to market.” What does that mean? Best in class service, more optionality, higher netbacks for your oil and gas production and better net burner tip pricing.
Working with you, we will evaluate your gathering, processing, pipeline delivery and marketing options and create a plan to maximize the potential of each. We will clearly explain your options and implement a strategy that brings you closer to market!
Take a look through our website and contact us to learn more about how Marabou can help you optimize your value. We offer years of experience at providing pipeline development and construction, natural gas and crude midstream marketing, enduser natural gas supply and resource management designed around your goals!
