Oil Spill Prevention Regulations: Suggestions for Improvement

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Oil Spill Prevention RegulationsSuggestions for
Improvement

• Alaska Department of Environmental Conservation
• Spill Prevention and Response Division
• Industry Preparedness Program

Craig Wilson May 3, 2005
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Contingency Plan Regulations Project (CPR)

• Multi-phase, multi-year project to
  comprehensively review and update the oil
  discharge prevention and contingency plan
  regulations in 18 AAC 75
• Phase 1 completed May 2004
• Currently in Phase 2

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Goals of the Phase 2

• Make the regulations efficient and enhance
  clarity.
• The regulations should fill in the gaps where
  other requirements are either non-existent or
  inadequate.
• The regulations should complement other
  requirements and form a comprehensive, coherent
  regulatory regime.
• Currency of standards.
• Present regulations last revised early 1990s.
• Predictability in enforcement.

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Schedule

• July 2004 Letter sent to all plan holders
• Asked five basic questions
• Solicited comments, suggestions
• November 2004 Public Workshop, Anchorage
• April 1, 2005 Discussion paper issued
• July 1, 2005 End of informal comment period
• Fall, 2005 Formal comment period on proposed
  rulemaking
• February 2006 New regulations adopted

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Discussion Paper

• Published April 1, 2005, available on website
• Designed to stimulate discussion
• Provides a target to shoot at for comments
• Nothing is fixed in stone at this point
• ADEC will be accepting informal comments on the
  paper until July 1, 2005

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Summary of Considered Changes

• Update references to third party standards and
  delete 18 AAC 75.090.
• Increase prevention training and documentation
  requirements.
• Preventative booming during vessel transfers for
  combustible liquids and unsegregated ballast
  water.
• Performance standard for lightering equipment for
  laden oil tank vessels and oil barges.
• Impermeable wellhead sumps for exploration and
  production wells and artificial islands.
• Leak detection requirements for crude oil
  transmission pipelines from 1 of daily
  throughput to .5 of daily throughput and add
  computational pipeline monitoring (CPM) system
  regulations.
• Shop-fabricated tanks under 50,000 gallon
  capacity must meet UL142 construction and STI
  SP001-03 inspection standards. Non-standard taken
  out of service by 2015.
• Vaulted, self-diked, and double-walled tanks are
  defined in regulation, and exempted from some
  secondary containment requirements.
• Adopt the NACE standard for cathodic protection
  for both tanks and piping.
• Adopt ASME B31.3 and B31.4 design standards and
  API 570 inspection standards for facility piping.
• Define facility oil piping.
• Revise the prevention plan portion of the c-plan,
  include annual self-certification requirement.
• Approval criteria for spill prevention training
  and the prevention plan portion of the c-plan.

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What Isnt Included

• Tanker Escort System
• Homeland Security / Terrorism Issues
• Pipeline valves / Federal pipeline standards
• Risk-based inspection under API 653
• Refined product pipelines
• Gathering lines
• Process flow lines
• ?

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Alaska Administrative Procedures Act (APA)

• Formal regulatory process governed by statute
• Governs process, format, style, and grammar
• Takes a minimum of 90 120 days to complete if
  no contentious issues

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18 AAC 75, Article 1 Oil Pollution Prevention

• Major changes listed in discussion paper
• Separating out spill prevention training
• Protective booming for combustible liquid
  transfers
• .5 leak detection standard for crude oil
  transmission pipelines
• CPM for pipelines
• UL142 standard for tank construction
• STI inspection standard
• Piping standards (API 570, ASME B31.3, B31.4)

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Prevention Training

• Moved into its own section expanded
• Listing of job descriptions and training level
  needed
• Maintain records for 5 years

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Oil Transfers from Vessels

• Protective booming for transfers of combustible
  liquids and oily ballast water
• Performance standard for lightering tank vessels
  and oil barges

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Exploration Production Facilities

• Changed offshore platform to marine structure
  
• Impermeable wellhead sumps for new wells onshore
  and on artificial islands

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Pipelines

• Leak detection
• Changed from 1 to .5 of daily throughput
• Computational Pipeline Monitoring (CPM)
• API 1130 Standard

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Aboveground Storage Tanks Secondary Containment

• Non-adoption of API 653 risk-based inspection
• UL 142 standard for tanks less than 50,000 gallon
  capacity
• STI SP001-03 inspection standard for shop
  fabricated tanks
• NACE 0193-2001 cathodic protection standard
• Recognition of double-walled and self-diked tank
  designs

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Facility Piping Definition

• facility oil piping means piping and associated
  fittings originating or terminating at an oil
  storage tank regulated under 18 AAC 75.065 or an
  exploration or production well, located within
  the boundaries of an oil terminal, crude oil
  transmission pipeline, exploration or production
  facility, including all valves, elbows, joints,
  flanges, pumps, and flexible connectors, up to
  the
• (A) Union of the piping with a fuel dispensing
  system
• (B) Marine header
• (C) Fill cap or fill valve
• (D) Forwarding pump used to transfer oil between
  facilities, between adjacent pump stations, or
  between a pressure pump station and a terminal or
  breakout tank
• (E) First flange or connection within the loading
  rack containment area or
• (F) First choke or valve inside a manifold
  building, or if a manifold building is not
  present at the well pad, the first choke or valve
  inside a gathering center or flow station

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Facility Piping

• ASME B31.3 B31.4 design standards
• API 570 inspection standards
• NACE RP0169-2002 standard for cathodic protection

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18 AAC 75, Article 4 Oil Discharge Prevention
Contingency Plans

• Revision of Prevention Plan contents
• Direct linkage to Article 1 requirements
• Annual prevention measures review certification
• Response Planning Standard documentation
  requirement
• Approval criteria for spill prevention training
  and prevention plan contents

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18 AAC 75, Article 9 - Definitions

• Where possible, definitions were moved into the
  appropriate sections.
• New definitions
• Cathodic protection
• Corrosion terms
• Placed in service/removed from service

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For More Information Updates

• Website - http//www.dec.state.ak.us/spar/ipp/cpr.
  htm
• Automated email list server
• Email Craig_Wilson_at_dec.state.ak.us
• Craig WilsonSpill Prevention Response
  DivisionAlaska Department of Environmental
  Conservation410 Willoughby Ave., Suite
  303Juneau, AK 99801voice [phone]fax
  [phone]