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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. Contingency Plan Regulations Project (CPR).

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oil spill prevention regulations suggestions for improvement

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

contingency plan regulations project cpr
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
goals of the phase 2
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.
  • 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
discussion paper
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
summary of considered changes
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.
what isn t included
What Isn’t 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
  • ?
alaska administrative procedures act apa
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
18 aac 75 article 1 oil pollution prevention
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)
prevention training
Prevention Training
  • Moved into its own section & expanded
  • Listing of job descriptions and training level needed
  • Maintain records for 5 years
oil transfers from vessels
Oil Transfers from Vessels
  • Protective booming for transfers of combustible liquids and oily ballast water
  • Performance standard for lightering tank vessels and oil barges
exploration production facilities
Exploration & Production Facilities
  • Changed “offshore platform” to “marine structure”
  • Impermeable wellhead sumps for new wells onshore and on artificial islands
  • Leak detection
    • Changed from 1% to .5% of daily throughput
  • Computational Pipeline Monitoring (CPM)
    • API 1130 Standard
aboveground storage tanks secondary containment
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
facility piping definition
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
facility piping
Facility Piping
  • ASME B31.3 & B31.4 design standards
  • API 570 inspection standards
  • NACE RP0169-2002 standard for cathodic protection
18 aac 75 article 4 oil discharge prevention contingency plans
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
18 aac 75 article 9 definitions
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
for more information updates
For More Information & Updates
  • Website - http://www.dec.state.ak.us/spar/ipp/cpr.htm
    • Automated email list server
  • Email – Craig_Wilson@dec.state.ak.us
  • Craig WilsonSpill Prevention & Response DivisionAlaska Department of Environmental Conservation410 Willoughby Ave., Suite 303Juneau, AK 99801voice: (907) 465-5204fax: (907) 465-5245