The Alaska Department of Environmental Conservation is implementing some new and revised regulations for preventing oil spills, Lydia Miner, manager of the DEC exploration, production and refineries section, told the Kenai Chapter of the Alaska Support Industry Alliance on Dec. 19. Miner explained that the regulations fit within DEC’s statutory responsibilities.
“Our mission is to keep oil in the container,” Miner said. “… We have statutory obligation and statutory authority to review oil discharge prevention and contingency plans.”
Miner said that the regulation changes come as part of what was initially envisaged as phase two of a four-phase regulation update process, which started around 2001, well before the oil spill issues that have arisen with the Prudhoe Bay transit lines. The changes for facility design and construction apply after Dec. 31, 2009, while regulations for facility operations, maintenance and inspections go into effect at the beginning of 2008.
Flowlines
Miner said that the new regulations include a new category of pipeline called a flowline, a category that emerged from some pipeline nomenclature confusion following the Prudhoe Bay oil spills.
“We took it upon ourselves to define what a flowline is and we used a definition that it is piping that carries oil between a well pad or offshore platform and a production facility,” Miner said.
Miner said that a flowline can act in reverse when used for injection into a well and that the flowline regulations can apply to multiphase and produced water lines, but not to seawater lines.
“Starting in 2009 you will have to be building your flowlines to certain standards,” Miner said. The new regulations spell out those standards. Flowlines installed before 2009 are exempt from the new construction standards, Miner said.
But starting in 2008 corrosion control will need to be in place for all flowlines, including flowlines installed before 2009. The regulations spell out different corrosion control for buried or submerged flowlines, as distinct from above ground flowlines. Flowline operators will also need to have a program such as cleaning pigs or the use of corrosion inhibitors to minimize internal corrosion.
By 2008 every flowline must either have a leak detection system or an acceptable preventive maintenance system. And all flowlines must be marked. Operators must keep documentation for corrosion control and preventive maintenance.
Facility oil pipelines — pipelines that originate or terminate in a regulated oil storage tank or an exploration or production well — are already regulated, Miner said. Current regulations require a protective coating and cathodic protection for this type of pipeline. But pipelines installed after the end of 2008 will require new standards for construction and cathodic protection. And facility oil pipelines must be subject to a specific inspection program starting in 2008.
Miner said that DEC is not changing the regulations for oil transmission lines at the moment but will be issuing changes to those regulations at some time in the future.
Oil storage tanks
For the new regulations, DEC has separated oil storage tanks into two categories: field-constructed tanks and shop-fabricated or portable tanks. Tanks are regulated if they are sited at a facility that holds more than 10,000 gallons of oil or that is required to have an oil spill contingency plan, Miner explained.
Current regulations went into effect on May 14 1992 — no construction standards apply to tanks installed before that date. Specific construction standards apply to field-constructed tanks installed after that date and new standards come into effect under the new regulations for field-constructed tanks installed after the end of 2008.
Current regulations also spell out inspection standards for field-constructed tanks, but from 2008 there is a new standard for cathodic protection and requirements for the internal inspection of elevated tanks have been relaxed.
“If you have elevated tanks you’ll want to look at the regulations to see if that applies to you,” Miner said.
There are no construction standards for portable tanks built prior to 2009, but from 2009 onwards new construction standards will apply. In addition, certain types of tank, such as double-walled tanks, will become exempt from the need for secondary containment requirements.
Miner also commented that portable tank overfill protection requirements remain a source of confusion; she asked that operators to contact her if they need clarification.
DEC has also made some minor changes to the regulations for fixed marine structures, such as offshore oil platforms. “The old regulations applied to Cook Inlet platforms and we’ve just made them fit more for what’s going on on the North Slope now,” Miner said.
Training requirements
DEC is placing increased emphasis on oil spill prevention training, and has moved training to its own section in the regulations.
“If you have personnel that inspect, maintain or operate oil storage and transfer equipment they must be trained regarding your company’s and the state’s spill prevention measures,” Miner said.
Miner said that DEC would be auditing for training requirements as part of people’s job descriptions and that training records must be kept for at least five years.
In presenting the regulation changes Miner acknowledged that industry seeks consistency in the regulatory environment. But she pointed out that the oil spill regulations have not changed since 1992.
“We’ve been pretty consistent for 14 years,” Miner said. “We believe that the changes to the regulations make them clearer — we think you’re going to have less surprises in interpretation from DEC regulators in the future.”
See regulation changes at www.dec.state.ak.us/spar/ipp.
