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Who regulates inlet pipelines? Soldotna forum hears from federal regulators: U.S. Department of Transportation and U.S. Coast Guard Kristen Nelson PNA Editor-in-Chief
Oil pipelines in Cook Inlet are usually in the spotlight only when there is a problem. A Jan. 10 forum in Soldota focused on what industry and regulators are doing to prevent problems, including overviews by major regulators of requirements and procedures.
The forum was sponsored by the Alaska Department of Environmental Conservation, the U.S. Department of Transportation, the Environmental Protection Agency, the U.S. Coast Guard, the Alaska Oil and Gas Association and Cook Inlet Regional Citizens Advisory Council.
Concerns of the Cook Inlet RCAC about the age of pipelines prompted discussions with pipeline operators and regulators, leading to the forum.
No single agency Jim Carter, the council’s executive director, said the council was created under the Oil Pollution Act of 1990 to partner with industry and government, representing the views of citizens. Under its OPA ‘90 mandates, the council reviews oil spill contingency plans for the crude oil facilities in Cook Inlet and works to promote safe environmental operation.
A 2000 study by the council found “there was no single agency coordinating the design, construction, maintenance, operation, oil spill response plans for pipelines in Cook Inlet,” Carter said, and the council said it was difficult to find out who was responsible for a lot of regulatory activities for Cook Inlet pipelines.
The council suggested a work group of itself, the regulators and the operators “to investigate how agencies and operators can address potential problems with pipelines in Cook Inlet.” Carter said the council was interested in identifying areas where regulatory agencies could develop cooperative agreements, examining methods to streamline regulatory functions and identifying additional prevention measures to incorporate into the state’s regulations.
Beginning of process Judy Brady, executive director of AOGA, said the forum was the beginning of a process to look at whether there were regulatory overlaps or gaps, review new technology that might be applicable “and determine what regulatory changes or additions are desired and needed.” Brady said the forum started as an opportunity for industry and regulators to sit down and talk about pipelines today, addressing concerns the Cook Inlet RCAC had raised. When DEC wanted to know what public concerns were, it was all rolled into one.
Susan Harvey, DEC industry preparedness and pipeline program manager, said DEC views the forum as a way to “provide the public with information on key issues pertaining to oil spill prevention for Cook Inlet pipelines ... and baseline information on the current status of the Cook Inlet oil pipeline integrity program.”
Harvey also said the commissioner of DEC “is particularly interested in knowing, should the state take primacy of the federal program like many other states have done? Should we look at accelerating what the federal requirements are? How should we fund it? Or should the state adopt their own special, more stringent regulations in addition tow hat the federal folks are giving? Or should we develop memorandums of understanding that coordinate that activity more efficiently?”
Who regulates pipelines Who regulates Cook Inlet pipelines now? Gerry Davis, a general engineer with the U.S. Department of Transportation’s Office of Pipeline Safety in Anchorage, said DOT inspects all pipelines in Alaska.
The Office of Pipeline Safety regulates all hazardous liquid lines in the United States, Davis said, and defines a hazardous liquid as petroleum, including crude oil, petroleum products, including fuel, and anhydrous ammonia.
That regulation is under the Pipeline Safety Act, which was reauthorized in December.
As far as Cook Inlet liquids lines go, he said, the Office of Pipeline Safety regulates all lines within the waterline of Cook Inlet except for the offshore loading line at Drift River.
And reporting regulations have just changed, Davis said.
“Effective Jan. 1 of 2002, releases of five gallons or more from a non-maintenance activity must be reported... Previous to January of 2002 it was 50 barrels.
“Releases of five barrels or approximately 210 gallons that are the result of a maintenance activity must also be reported and previously that was also 50 barrels,” he said.
Any spill that results in a death or bodily harm, damages of $50,000 or more and any condition on a pipeline that affects the integrity or safety of the pipeline must also be reported. The DOT also requires reports of all pipelines abandoned in navigable waters.
DOT design requirements DOT regulations cover pipeline design, which must withstand not just internal pressure, but any external forces that can be anticipated. Valves and fittings are also covered in DOT’s code, Davis said.
The code requires pipeline design to follow industry standards established by such organizations as the American Petroleum Institute.
All new pipelines, he said, must be designed so that internal inspection devices or smart pigs can be run through them. While DOT doesn’t require a leak detection system, if there is one is must be designed in accordance with API standards.
DOT also regulates construction of pipelines, requiring joints to be welded in accordance with the strictest industry standards, Davis said. Welders must be qualified and there must be records of their qualifications. Welds must be inspected.
A cathodic protection system must be installed within one year of construction to prevent corrosion.
DOT requires that pipe be coated and that the coating be inspected just prior to laying it into the trench, or just prior to installing it from a lay barge or just prior to pulling it in a directional drill.
The pipeline must have safety devices to prevent over-pressuring during operation and it must have emergency shutdown devices on the pumping system so it can be isolated and shut down immediately.
The pipeline must also have adequate cover, Davis said, both onshore and offshore lines. It must be pressure tested to 125 percent of maximum operating pressure.
If a pipeline can be visually inspected during pressure testing it has to be tested at 125 percent of maximum operating pressure for four hours; if you cannot see the pipe, you need to add four hours to the test.
DOT testing and inspection David said DOT is primarily looking at operation and maintenance when they do a pipeline inspection, including emergency response procedures and records of how work is done. And DOT goes out and looks at the lines.
If DOT finds an unsafe condition, it requires the operator to correct that condition within a reasonable amount of time. What that amount of time is, Davis said, can vary from a few months to a year, depending on what the unsafe condition is.
“The only time that that doesn’t apply would be is if there is an immediate hazard to persons or property. Then that particular part of the system cannot be operated until that unsafe condition has been corrected,” he said.
DOT looks at the manuals for pipeline procedures — do they have startup and shutdown procedures? Do they monitor pipeline pressures and how do they monitor pressures? How do they abandon pipeline segments? Do they have procedures for liaison with the local fire department and police department? Patrolling procedures for bi-weekly patrols?
Pipeline companies are also required to annually review all of their procedures to make sure that they are complete and effective, Davis said.
What DOT looks at In Cook Inlet, the Office of Pipeline Safety completed inspections last year of all facilities except Spurr and Spark, Davis said. In 2002, “we will be inspecting all of the Cook Inlet liquids facilities and that will include the Spurr and the Spark,” he said.
In an inspection, “we review all the records: everything that an operator is required to do under our code, he’s required to have a record for,” he said.
Sometimes, he said, “we actually see things that may have been overlooked” such as maintenance activities. Procedures are reviewed to make sure they are current and complete.
“We review all the conditions that should have been reported to ensure that they were reported. And then we go out on the facility itself and we do a visual inspection.” Davis said that even when a pipeline is underground, you can look at aboveground facilities. It is also an opportunity to talk with people who are working on things like corrosion control and pressure testing, he said: “talk to the individuals and make sure that we feel that they know what they’re doing.”
How DOT ha If deficiencies are found, action depends on the severity of the problem and the past history of the company, Davis said.
For inadequate procedures the agency will issue a notice of amendment and require the operator to change procedures to comply with DOT’s code. If a violation doesn’t affect integrity and there is no history of it happening in the past, “we’ll issue a warning letter that doesn’t require any response from the operator and we basically say, don’t do this again, or the next time something’s going to happen.”
Compliance orders proscribe actions that an operator is required to do within a given amount of time to bring a facility back into compliance, Davis said.
Compliance orders and warning letters all go through the agency’s legal counsel in Washington, D.C., before the final order is given.
“But it’s possible,” he said, “for a hazardous facility order to be given immediately and require an operator to do something immediately.”
Coast Guard Mark McManus, with the U.S. Coast Guard’s Marine Safety Detachment in Kenai, said the Coast Guard has a mixed bag of missions in the area including vessel inspections and inspections of the marine transfer section of pipelines, both onshore facilities and on platforms.
That includes the portion of a facility “from where the vessel connects to the first valve inside the secondary containment.”
Those facilities are typically a small section of the pipeline, he said, although the Coast Guard does have responsibility for the lines at Drift River that carry crude oil out to the Christy Lee platform.
“It’s really a small window of operations … we’re not regulating the production side of the facility nor the pipeline itself,” McManus said.
The Coast Guard is also the federal on-scene coordinator for any spills on or within 1,000 feet of navigable waterway and is required to be notified of any spill that creates a sheen on the water.
Editor’s note: State regulations, new federal requirements and industry’s analysis of Cook Inlet pipelines will be covered in future issues of PNA.
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