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Significant New LP Gas Safety Rules Adopted


New rules will be effective on July 18, 2022 At its Commissioners Conference on June 28, 2022, the Railroad Commission adopted final changes to the LP Gas Safety Rules. The new rulemaking will be published in the Friday, July 15, 2022, issue of the Texas Register. The effective date of the Chapter 9 adoption is Monday, July 18, 2022. The new final Texas LP Gas Safety rules are years in the making, and we thank our TPGA Technical & Standards Committee, TPGA team, and other TPGA members who assisted in making several of these rules come to fruition. We are also appreciative of the Commission leadership and legal staff that listened to our concerns and made several requested changes from the original proposed rules.

Adopted Technology Changes

At the request of members and the Texas Propane Gas Association, the Commission is now allowing the use of newer technology. 1. Electronic actuators will now be allowed under LP Gas Safety Rules §9.126 Appurtenances & Equipment and §9.143 Piping & Valve Protection for Stationary LP-Gas Installations. 2. Engineered breakaways on risers will now be allowed under §9.143. Piping and Valve Protection for Stationary LP-Gas Installations.

Changes to System Protection Requirements

3. §9.140 (c) (3) states ASME containers or manual dispensers originally manufactured to or modified to be considered by AFS as self-contained units are exempt from the fencing requirements. 4. §9.140 (d) (3) states locations with a perimeter fence prohibiting public traffic to the container or cylinder storage area shall not be required to have guard railing if the vertical supports are located no more than three feet apart. 5.In addition to the NPGA's 20 lb cylinder impact study that proves the cage itself is adequate protection, TPGA was able to provide the Commission with a ProCOT report from Bison Engineering outlining the low incident rates at facilities not frequented by the public that store and use propane forklift cylinders. As a result, under §9.140 (g) RRC will now recognize that DOT cylinders stored in ventilated cages do not require additional protection unless they meet two exceptions are stored horizontally and are frequented by the public. Cylinders stored horizontally in areas "frequented by the public" will need additional protection (e.g. wheel stops, curbs, etc).

Fire Safety Analysis

6. At the request of TPGA, new rules amendments to NFPA 58 table section 6.29.3.2 found in §9.403 clarify that Fire Safety Analysis is not required until September 1, 2022, for 10,000 gallons and above. The fire safety analysis shall be an evaluation of the total product control system, such as the emergency shutoff and internal valves equipped for remote closure and automatic shutoff using thermal (fire) actuation, pull away protection where installed, and other optional requirements. The Commission is in the process of updating the PERC Fire Safety Analysis forms to reflect 2017 NFPA 58 and Commission rules and hopes to make them available by the compliance deadline.

Proposed Training Related Changes

7. Under §9.52, one of the concessions, the Commission didn't make is that they removed the option for managers to take CETP for continuing education stating that CETP does not teach RRC LP Gas Safety Rules. The RRC will roll out a new 6.1 Regulatory Managers Continuing Education class designed to update managers on rule changes that may have occurred since their last training four years prior. 8. At the request of TPGA and its members, the new LP Gas Safety Rule §9.20 will exempt both DOT cylinder fillers and motor/mobile fuel fuelers from RRC training and exam requirements for initial certification for those employees who take the PERC Dispensing Propane Safely Training and exam through PERC's online Learning Center at https://training.propane.com/ and submit the new Form16P with a $40 fee. 9. New LP Gas Safety Rule §9.55 allows employees to have the option to take "PERC-based" Dispensing Propane Safely Training either instructed by someone within their company or by an outside company facilitating training rather than take the 2.1 initial course of instruction at the Commission. The Commission will require companies providing PERC-based training to complete the new PERC-Based Training Application form as well as review and approve their course materials.

Other Changes

10. Changes to §9.134 state that the licensee is no longer required to submit LPG Form 22 only if the piping system is currently in service and no new piping is installed, the system is in good working order, and the installer cannot be determined. 11. Due to TPGA and industry concerns, the Commission did not adopt the proposed §9.7, a proposed blanket 24-hour emergency number requirement because it is not applicable to all types of licenses and registrations, particularly those that do not have hazard exposure.

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Just a reminder that these new rules do not become effective until July 18, 2022.

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