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Oil Spill Prevention Regulations: Suggestions for Improvement Alaska Department of Environmental Conservation Spill Prevention and Response Division Industry.

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Presentation on theme: "Oil Spill Prevention Regulations: Suggestions for Improvement Alaska Department of Environmental Conservation Spill Prevention and Response Division Industry."— Presentation transcript:

1 Oil Spill Prevention Regulations: Suggestions for Improvement Alaska Department of Environmental Conservation Spill Prevention and Response Division Industry Preparedness Program Craig Wilson May 3, 2005

2 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 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 Phase 1 completed May 2004 Currently in Phase 2 Currently in Phase 2

3 Goals of the Phase 2 Make the regulations efficient and enhance clarity. 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 “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. The regulations should complement other requirements and form a comprehensive, coherent regulatory regime. Currency of standards. Currency of standards. Present regulations last revised early 1990s. Present regulations last revised early 1990s. Predictability in enforcement. Predictability in enforcement.

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

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

6 Summary of Considered Changes Update references to third party standards and delete 18 AAC 75.090. Update references to third party standards and delete 18 AAC 75.090. Increase prevention training and documentation requirements. Increase prevention training and documentation requirements. Preventative booming during vessel transfers for combustible liquids and unsegregated ballast water. 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. Performance standard for lightering equipment for laden oil tank vessels and oil barges. Impermeable wellhead sumps for exploration and production wells and artificial islands. 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. 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. 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. 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 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. Adopt ASME B31.3 and B31.4 design standards and API 570 inspection standards for facility piping. Define “facility oil piping”. Define “facility oil piping”. Revise the prevention plan portion of the c-plan, include annual self-certification requirement. 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. Approval criteria for spill prevention training and the prevention plan portion of the c-plan.

7 What Isn’t Included Tanker Escort System Tanker Escort System Homeland Security / Terrorism Issues Homeland Security / Terrorism Issues Pipeline valves / Federal pipeline standards Pipeline valves / Federal pipeline standards Risk-based inspection under API 653 Risk-based inspection under API 653 Refined product pipelines Refined product pipelines Gathering lines Gathering lines Process flow lines Process flow lines ?

8 Alaska Administrative Procedures Act (APA) Formal regulatory process governed by statute Formal regulatory process governed by statute Governs process, format, style, and grammar Governs process, format, style, and grammar Takes a minimum of 90 – 120 days to complete if no contentious issues Takes a minimum of 90 – 120 days to complete if no contentious issues

9 18 AAC 75, Article 1 – Oil Pollution Prevention Major changes listed in discussion paper Major changes listed in discussion paper Separating out spill prevention training Separating out spill prevention training Protective booming for combustible liquid transfers Protective booming for combustible liquid transfers.5% leak detection standard for crude oil transmission pipelines.5% leak detection standard for crude oil transmission pipelines CPM for pipelines CPM for pipelines UL142 standard for tank construction UL142 standard for tank construction STI inspection standard STI inspection standard Piping standards (API 570, ASME B31.3, B31.4) Piping standards (API 570, ASME B31.3, B31.4)

10 Prevention Training Moved into its own section & expanded Moved into its own section & expanded Listing of job descriptions and training level needed Listing of job descriptions and training level needed Maintain records for 5 years Maintain records for 5 years

11 Oil Transfers from Vessels Protective booming for transfers of combustible liquids and oily ballast water Protective booming for transfers of combustible liquids and oily ballast water Performance standard for lightering tank vessels and oil barges Performance standard for lightering tank vessels and oil barges

12 Exploration & Production Facilities Changed “offshore platform” to “marine structure” Changed “offshore platform” to “marine structure” Impermeable wellhead sumps for new wells onshore and on artificial islands Impermeable wellhead sumps for new wells onshore and on artificial islands

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

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

15 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: “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; (A) Union of the piping with a fuel dispensing system; (B) Marine header; (B) Marine header; (C) Fill cap or fill valve; (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; (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 (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 (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

16 Facility Piping ASME B31.3 & B31.4 design standards ASME B31.3 & B31.4 design standards API 570 inspection standards API 570 inspection standards NACE RP0169-2002 standard for cathodic protection NACE RP0169-2002 standard for cathodic protection

17 18 AAC 75, Article 4 – Oil Discharge Prevention & Contingency Plans Revision of Prevention Plan contents Revision of Prevention Plan contents Direct linkage to Article 1 requirements Direct linkage to Article 1 requirements Annual prevention measures review & certification Annual prevention measures review & certification Response Planning Standard documentation requirement Response Planning Standard documentation requirement Approval criteria for spill prevention training and prevention plan contents Approval criteria for spill prevention training and prevention plan contents

18 18 AAC 75, Article 9 - Definitions Where possible, definitions were moved into the appropriate sections. Where possible, definitions were moved into the appropriate sections. New definitions New definitions Cathodic protection Cathodic protection Corrosion terms Corrosion terms Placed in service/removed from service Placed in service/removed from service

19 For More Information & Updates Website - http:// www.dec.state.ak.us/spar/ipp/cpr.htm Website - http:// www.dec.state.ak.us/spar/ipp/cpr.htmhttp:// www.dec.state.ak.us/spar/ipp/cpr.htmhttp:// www.dec.state.ak.us/spar/ipp/cpr.htm Automated email list server Automated email list server Email – Craig_Wilson@dec.state.ak.us Email – Craig_Wilson@dec.state.ak.us Craig_Wilson@dec.state.ak.us Craig Wilson Spill Prevention & Response Division Alaska Department of Environmental Conservation 410 Willoughby Ave., Suite 303 Juneau, AK 99801 voice: (907) 465-5204 fax: (907) 465-5245 Craig Wilson Spill Prevention & Response Division Alaska Department of Environmental Conservation 410 Willoughby Ave., Suite 303 Juneau, AK 99801 voice: (907) 465-5204 fax: (907) 465-5245


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