Texas’ Winterization Legislation

November 16, 2023by Travis Richards
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What’s Required, How Effective is it, and How can Catco Help Suppliers Meet Regulations?

Texas is known for its unpredictable weather patterns, with significant fluctuations in temperature throughout the year. These climate shifts can have substantial implications for both natural gas facilities and the population of Texas as a whole. Extreme hot and cold swings pose challenges for maintaining the reliability and stability of natural gas infrastructure and can potentially impact the availability of electricity for Texans.

Recognizing the need to address these issues and prevent future energy crises, the Railroad Commission of Texas (RRC) introduced new regulations aimed at the natural gas industry, specifically designed to safeguard the flow of gas to power generators, ensuring that Texans have access to electricity, especially during times of natural disasters or severe weather conditions. These regulations were officially put in place in December 2022. 

What is a “winterization regulation”? 

Winterization regulations focus on ensuring the reliability and resilience of power generation, transmission and distribution systems during winter months and include specific measures to protect equipment and infrastructure from freezing, prevent ice buildup and maintain the stability of energy supply. 

Typically, winterization regulations require companies and facilities to take various actions, such as insulating pipes and equipment, implementing heating systems or anti-freeze measures, developing contingency plans to address potential weather-related disruptions and conducting regular maintenance and inspections.

Why are there new regulations?

In February 2021, Winter Storm Uri brought extremely cold weather to Texas, with some areas experiencing highly unusual subzero temperatures. The extreme cold temperatures and freezing conditions caused a surge in demand for natural gas for heating purposes. At the same time, the freezing temperatures caused issues with wellheads, pipelines and processing facilities, hampering the extraction and distribution of natural gas. 

With limited supply, many gas-fired power plants faced difficulties operating at full capacity or had to shut down altogether. This reduction in power generation capacity contributed to the widespread power outages experienced across the state during the winter storm, leaving millions of people without electricity for days or even weeks. 

Not only did the loss of power create issues with transportation, housing, water and food, the storm tragically resulted in multiple fatalities and injuries. To better protect Texas from experiencing events like this, 16 Texas Administrative Code (TAC) §3.66, relating to Weather Emergency Preparedness Standards, requires critical gas facilities to weatherize their operations and participate in regular government-led inspections.

What do the new regulations entail?

16 TAC §3.66 requires gas supply chain facilities designated as critical under 16 TAC §3.65 and included on the electric supply chain map to file a Weather Emergency Readiness Attestation and undergo annual inspections. 

16 TAC §3.65 defines critical gas supply chain facilities as “gas wells producing gas in excess of 250 Mcf/day; gas processing plants; natural gas pipelines and pipeline facilities including associated compressor stations and control centers; local distribution company pipelines and pipeline facilities including associated compressor stations and control centers; underground natural gas storage facilities; natural gas liquids transportation and storage facilities; and saltwater disposal facilities including saltwater disposal pipelines.”

Each year, these critical facilities must also submit Weather Emergency Readiness Attestation to the RRC by December 1 every year. This document must be prepared by an authorized representative of the operator or someone working under the authorized representative’s supervision and show that the facility has undergone appropriate weather emergency preparedness measures, including:

    1. correcting critical component failures that occurred during previous weather emergencies; 
    2. installing equipment to mitigate weather-related operational risks; and 
    3. internal inspection, self-assessment and implementation of processes to identify, test and protect critical components.

Have weatherization efforts helped the state of Texas since being implemented?

Since these regulations are still fairly new, their overall effectiveness is still unknown. Ramanan Krishnamoorti, vice president of energy and innovation at the University of Houston, told ABC News, “The tests to the grid these past two winter seasons have not acted as ‘true stress tests.’ The current freeze is ‘much less intense’ in terms of temperature and temperament, compared to the back-to-back winter storms of 2021 that caused a statewide energy catastrophe.” 

According to this article in Texas Monthly, the state still has trouble delivering the natural gas needed during the coldest winter months. Some power plants had difficulty obtaining enough natural gas to burn and had to rely on backup fuel oil (which is slowly being phased out because of its high carbon levels). 

While some consider the natural gas issue still not properly addressed by these legislative measures, the hope is that these efforts are more of an ongoing assessment to determine what is and isn’t working when delivering electricity to Texas citizens, especially in times of extreme need.

How can Catco help natural gas facilities with their winterization efforts?

Catco’s catalytic heaters generate heat without a flame, making them ideal for use in many hazardous environments, including helping Texas’s critical natural gas facilities comply with the previously noted state winterization regulations, specifically in mitigating weather-related operational risks. 

Catco’s full line of heaters and automation systems apply catalytic heating technology to all phases of the natural gas extraction and delivery process to help companies prevent downtime. For example:

    • Catco’s heated enclosure packages mount directly to valves to eliminate ice buildup when ambient temperatures are low or when there is a pressure drop across a regulator.
    • Catco’s instrument gas heaters preheat gas before it reaches the pilot in pilot-operated regulators. They can also be used to heat a stream of gas for measurement or instrumentation.
    • Catoc’s space heaters are perfect for situations that require heat but are not suitable for traditional heating because of the presence of explosive gases or lack of electricity. Wall or floor-mounted catalytic heaters can maintain a comfortable environment for personnel or prevent equipment from reaching critical temperatures.

They not only provide an additional source of heat to supplement a facility’s existing heating system, but during times of extreme weather, they can reduce the typical strain put on those heating systems and decrease the risk of equipment failure. 

Where ABC News reports some facilities have “installed hundreds of millions of dollars worth of updates to better winterize their facilities,” catalytic heaters are a fast and cost-effective solution when comparing the massive capital expenditure and amount of time that total equipment and pipeline upgrades can require.

If you’re operating a critical natural gas facility and are not using catalytic heaters, call one of our Catco representatives today to find out how we can help you comply with recent Texas regulations and more efficiently operate your business.

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