New LP Gas Safety Rule Highlight Operations & Maintenance Manual
In 2004, the NFPA adopted a requirement that installations over 4,000 gallons have an Operations & Maintenance Manual. Since then, Texas has had an exception to this NFPA 58 requirement. However, in the latest LP Gas Safety rule adoption, the Railroad Commission of Texas has adopted this chapter of the NFPA 58 2017 edition, but with an exception. The exception is the requirement is triggered at a higher threshold than what NFPA requires. While existing bulk plant & industrial installations over 10,000 gallons aggregate and above are NOT required to comply until September 1, 2021, new plants installed after September 1, 2020, with an aggregate water capacity of 10,000 gallons or more and all pipeline LP-Gas systems are expected to have one. The Texas Propane Gas Association has been working with the Railroad Commission to get more guidance on what the RRC would like to see in an Operations & Maintenance (O & M) Manual. The RRC has agreed to develop and share a checklist and provide more guidance. TPGA will share this information with members to help them develop a manual when we receive it. A couple of compliance associate members have also reached out to us saying they provide O & M manuals as a service. Since this is a new requirement and guidance is still forthcoming, the RRC will not prevent plants from going into service if they do not have an O & M manual after September 1st, however, RRC may issue a warning. RRC does not expect many industry folks to be affected by the new requirement in the imminent future since it is limited to "new" large bulk plants.