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TITLE 16ECONOMIC REGULATION
PART 1RAILROAD COMMISSION OF TEXAS
CHAPTER 3OIL AND GAS DIVISION
RULE §3.97Underground Storage of Gas in Salt Formations

  (9) Annual emergency drill. Annually, each operator shall conduct a drill that tests response to a simulated emergency. Written notice of the drill shall be provided to the appropriate Commission district office, the county emergency management coordinator, and the county sheriff's office at least seven days prior to the drill. Local emergency response authorities shall be invited to participate in all such drills. The operator shall file a written evaluation of the drill and plans for improvements with the appropriate district office and the county emergency management coordinator within 30 days after the date of the drill.

  (10) Employee safety training.

    (A) Each operator shall prepare and implement a plan to train and test each employee at each underground gas storage facility on operational safety to the extent applicable to the employee's duties and responsibilities. The facility's emergency response plan shall be included in the training program.

    (B) Each operator shall hold a safety meeting with each contractor prior to the commencement of any new contract work at an underground gas storage facility. Emergency measures, including safety and evacuation measures specific to the contractor's work, shall be explained in the contractor safety meeting.

  (11) Fire suppression capability.

    (A) Within three years of the effective date of this section, each operator shall have fire suppression capability designed to aid in personnel rescue and equipment protection and cooling.

    (B) Within one year of the effective date of this section, the operator may request an exception to the schedule or fire suppression requirement of this paragraph and propose an alternative schedule or means of protection from wellhead fire for approval of the Commission or its designee.

  (12) Wellhead, piping, and associated valves. All wellhead surface piping and associated valves shall be designed, installed, and operated in accordance with engineering standards to the expected service conditions to which the piping and equipment will be subjected.

  (13) Barriers. Within one year of the effective date of this section, barriers designed to prevent unintended impact by vehicles and equipment shall be placed around above grade hydrocarbon piping, hydrocarbon process equipment where vehicles may normally be expected to travel, or within 100 feet of a public road.

(i) Cavern capacity and configuration.

  (1) Before storage operations begin. The capacity and configuration of each gas storage cavern (both salt domes and bedded salt) shall be determined by sonar survey before storage operations begin in a newly completed cavern.

  (2) Salt domes. The capacity and configuration of each salt dome gas storage cavern shall be determined by sonar survey before a cavern that has been out of service is returned to service, provided, however, that a sonar survey shall not be required on a cavern that is being returned to service if a sonar survey of that cavern has been run at any time during the previous 10 years.

  (3) Bedded salt. The configuration of the roof of each gas storage cavern in bedded salt shall be determined by downhole log or an alternate method approved by the Commission, or its designee, at least once every five years.

  (4) Filing of results. Sonar and roof monitoring survey results shall be filed with the Commission within 30 days after the survey.

  (5) Out-of-service caverns. A sonar or roof monitoring survey is not required for a cavern that is out of service. A sonar or roof monitoring survey shall be performed before any such cavern that has been out of service is returned to service, unless the provisions of paragraph (2) of this subsection apply.

  (6) Verification. Sonar surveys performed before debrining shall be verified by metering the volume of the displaced brine.

(j) Well completion, casing, and cementing. Gas storage wells shall be cased and the casing strings cemented to prevent gases from escaping to the surface or into fresh water strata, or otherwise escaping and causing waste or endangering public safety or the environment.

  (1) New wells.

    (A) All gas storage wells drilled in salt domes after the effective date of this section shall have at least two casing strings cemented into the salt formation. Sufficient cement shall be used to fill the annular space outside the casing from the casing shoe to the ground surface, or from the casing shoe to a point at least 200 feet above the shoe of the previous casing string.

    (B) All gas storage wells drilled in bedded salt after the effective date of this section shall have all casing strings cemented with sufficient cement to fill the annular space outside each casing string from the casing shoe to the ground surface.

  (2) Well completion report. A well completion report shall be filed in accordance with the instructions on the form prescribed by the Commission within 30 days after a storage well is completed and before solution mining to create the cavern begins.

(k) Operating pressure.

  (1) Not to exceed maximum. The operating pressure of each gas storage well shall not exceed the permitted maximum allowable operating pressure for that well. The permitted maximum allowable operating pressure is that pressure specified in the Commission permit or order, or, if not specified in the permit or order, that pressure stated in the application or the application for amendment to a permit or order.

  (2) At casing seat. The maximum operating pressure at the casing seat shall not exceed 0.85 pounds per square inch per foot of depth.

(l) Monitoring requirements.

  (1) Gas pressure. Gas pressure on the injection/withdrawal casing or tubing or piping connected thereto shall be equipped with a pressure sensor to continuously monitor the wellhead pressure. Pressure sensors shall be integrated electronically with the warning systems, alarms, and emergency shutdown valve actuation system as required in subsection (h)(2)(B) and (h)(6)(A) of this section.

  (2) Pressure observation valves. The injection/withdrawal casing or tubing shall be equipped with a pressure observation valve and gauge. The wellhead shall be equipped with a pressure observation valve on each casing annulus so that a gauge may be installed for pressure monitoring.

  (3) Volumes injected and withdrawn. The volume of gas injected into and withdrawn from each storage well shall be measured by:

    (A) flow meter for each well; or

    (B) an alternate method approved by the Commission.

  (4) Meter calibration. Meters that measure the volume of gas into storage and out of storage shall be recalibrated at least once each year.

  (5) Data recording. Within three years of the effective date of this section, operators shall have installed and have functioning equipment to electronically record all liquid and gas pressures and injection volumes and rates at a frequency of at least once per minute, and all actuations of the emergency shutdown valve.

(m) Reporting.

  (1) Monthly reports. On or before the last day of each month, the operator of each facility that stores gas to supply a public utility shall file with the Commission a report showing the volume of gas placed into storage and the volume of gas removed from storage at the storage facility, during the preceding month. The report shall also state the total volume of gas in storage on the first and last days of the preceding month. This report shall be filed in a format acceptable to the Commission or its designee.

  (2) Annual reports. The operator shall file annually a status report for each storage well in accordance with the instructions on the form prescribed by the Commission.

(n) Operations, construction, and maintenance records retention.

  (1) Operations data.

    (A) The operator shall retain for at least three months all electronic records of storage well pressures, volumes of gases injected and withdrawn, and the inventory of gas in storage. These electronic data shall be recorded at a frequency of at least once per minute.

    (B) The operator shall retain for at least five years the records reported to the Commission under subsection (m). These electronic data shall be recorded at a frequency of at least once per day.

  (2) Records retention. The operator shall retain for at least five years the records of measurement performance under subsection (l)(4) of this section; and testing of safety devices under subsection (h) of this section. Records of any test of a safety device required under subsection (h) of this section shall be available for on-site inspection within 10 days of the date of the test.

  (3) Construction and maintenance data. The operator shall retain for the life of the facility documents and records pertaining to the drilling, mining, completion, repair and workover of storage wells and the testing of storage well integrity, and shall transfer all such documents and records to any new owner and/or new operator of the facility.

  (4) Extension during investigation. The operator shall retain beyond the prescribed retention period any documents or records that contain operational data pertaining to the resolution of any pending regulatory enforcement proceedings until the resolution of such proceedings.

(o) Testing and maintenance.

  (1) Integrity tests. Each gas storage well shall be tested for integrity prior to being placed into service, at least once every five years, and after each workover that involves physical changes to any cemented casing string. The following requirements apply to such integrity tests.

    (A) A test procedure shall be filed with the Commission for approval at least 10 days before the test date.

    (B) The initial test conducted on a well prior to placing it into service shall be performed using the nitrogen-interface test method or an alternative method approved by the Commission or its designee.

    (C) The integrity test required to be conducted at least once every five years on a well that has gas in storage may be performed using pressure monitoring, provided:

      (i) the wellhead pressure is stabilized such that the effects of ambient temperature on pressure have overtaken the effects of the last injection or withdrawal on pressure;

      (ii) a downhole temperature log is run at the beginning and at the end of the test period;

      (iii) the test period is a minimum of 72 hours; and

      (iv) the net gas volume change for the test period is calculated.

    (D) The operator shall notify the district office at least five days prior to conducting any integrity test.

    (E) A complete record of each integrity test shall be filed in duplicate with the district office within 30 days after testing is completed. The record shall include a chronology of the test, copies of all downhole logs, storage well completion information, pressure readings, volume measurements, temperature logs and readings, and an explanation of the test results that addresses the precision of the test in terms of a calculated leak rate.

  (2) Alternative monitoring. An operator may request the Commission or its designee to approve well pressure monitoring as an alternative to integrity testing for storage wells that are out of gas storage service. An out-of-service well shall be tested for integrity by the nitrogen-interface method before it may be returned to storage service.

  (3) Storage wellhead and casing. Storage wellhead components and casing shall be inspected at least once every 15 years for corrosion, cracks, deformations, or other conditions that may compromise integrity and that may not be detected by the five-year test. The operator may request an extension of up to five years from the Commission for good cause. Factors the Commission may consider in determining good cause pursuant to this paragraph include by are not limited to the age, location, and configuration of the well; well and facility history; operator compliance record; operator efforts to comply with this subsection; and accuracy of inventory control.

  (4) Fresh water, brine, and gas surface piping. Within one year of the effective date of this section, the operator shall submit a piping integrity management plan for approval by the Commission or its designee. Within three years of the effective date of this section, or in conjunction with the storage well integrity testing, all gas, freshwater, and brine surface piping shall be maintained according to the facility's piping integrity management plan.

(p) Plugging.

  (1) Plug on abandonment. A gas storage well shall be plugged upon permanent abandonment in a manner approved by the Commission or its designee. A proposal for plugging shall be submitted to the Commission in Austin for approval or modification prior to plugging. Following approval of a plugging plan, the operator shall file notification of intent to plug at least five days prior to commencement of plugging operations. A plugging report shall be filed with the Commission within 30 days after plugging.

Cont'd...

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