Kevin C. Connors Pipeline Program Supervisor

Transcription

1 Underground Gathering Pipelines: Building a Regulatory Program Kevin C. Connors Pipeline Program Supervisor kcconnors@nd.gov 600 East Boulevard Ave. Dept 405 Bismarck, ND (701)

2 Focused on Underground Gathering Pipelines Pipelines designed or intended to transfer crude oil, gas, or produced water from a production facility for disposal, storage, or sale purposes. Program Goal: Improve underground gathering pipeline safety and integrity; Safe transportation of fluids.

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4 Estimate 12,700 miles pre August ,900 miles August 2011-December ,650 miles per year (=17920 miles) = 36,000 miles (circumference around the world at the equator is about 24,902 miles) 11,171 miles within OGD database

5 The creation of the Pipeline Program stems from a pattern of major pipeline spills (crude oil and produced water) followed by legislation, then rule making, followed by major pipeline spills, followed by legislation, and now we are beginning another rule making. Program Goal: Reduce the number of small spills and try to eliminate the large spills through proper installation, monitoring and leak detection, and effective spill response.

6 House Bill 1333 North Dakota Century Code Section o The submission of GIS data on oil and gas underground gathering pipelines is required. o (Aug. 1, 2011 or newer) Currently 11,171 miles in Database o GIS data is confidential. o Allows owner or tenant to request pipeline locations within bounds of real property. o Allows Tax Dept. access to information. o Effective July 1 st, 2013.

7 North Dakota Administrative Code (NDAC) Sec (Pipeline Installation) Rules Effective 4/1/14 All newly constructed underground gathering pipelines must be: o Devoid of leaks o Resistant to external corrosion o Resistant to the effects of transported fluids o Installed in a manner that minimizes interference with: o Agriculture o Road & utility construction o Introduction of secondary stresses o Possibility of damage to the pipe o Tracer wire buried with nonconductive pipe installed o Backfilled in a manner that provides firm support under the pipe and prevents damage to the pipe and the pipe coating from equipment or from the back fill material. Abandoned pipeline o Physically isolate from operating system o Purge with water, air, or inert gas to remove all fluid o Cap or plug ends of abandoned line

8 House Bill 1358 North Dakota Century Code Section o o Upon request, the operator shall provide the commission the underground gathering pipeline engineering construction design drawings, list of independent inspectors, and a plan for leak detection (after August 1, 2015). Within 60 days of an underground gathering pipeline being placed into service, the operator of that pipeline shall file with the commission an independent inspector s certificate of hydrostatic or pneumatic testing of the underground gathering pipeline. o Commission may now require a bond (amendment to ). o Surface owner may now share GIS information (amendment to ). o The commission shall adopt the necessary administrative rules necessary to improve produced water and crude oil pipeline safety and integrity. o Effective April 20th, 2015.

9 House Bill 1358 EERC Study and Pilot Demonstration Project SECTION 8 o $1,500,000 for the purpose of funding a special project through the energy and environmental research center (EERC) at the university of North Dakota during the biennium beginning July 1, 2015, and ending June 30, The special project must focus on conducting an analysis of crude oil and produced water pipelines including the construction standards, depths, pressures, monitoring systems, maintenance, types of materials used in the pipeline including backfill, and an analysis of the ratio of spills and leaks occurring in this state in comparison to other large oil and gas-producing states with substantial volumes of produced water. o The NDIC shall contract with the EERC to compile the information and the center shall work with the department of mineral resources to analyze the existing regulations on construction and monitoring of crude oil and produced water pipelines, determine the feasibility and cost effectiveness of requiring leak detection and monitoring technology on new and existing pipeline systems, and provide a report with recommendations to the industrial commission and the energy development and transmission committee by December 1, The industrial commission shall adopt the necessary administrative rules necessary to improve produced water and crude oil pipeline safety and integrity. In addition, the industrial commission shall contract for a pilot project to evaluate a pipeline leak detection and monitoring system.

10 o Phase I Provided the report with recommendations to the NDIC and the Energy Development and Transmission Committee on December 1st, Report Infrastructure Leaks and Spills Statistics Materials Construction Maintenance and Inspection Monitoring and Leak Detection Abandonment o Phase II Demonstration Pilot project will evaluate the best available technology for pipeline leak detection and monitoring systems. $1.5M in state funding covers both phases

11 DMR should encourage real-time data sharing among pipeline partners. (1) Operators should be encouraged to incorporate technologies such as supervisory control and data acquisition (SCADA) to improve communication within and between operators. (21)

12 ND should streamline the ways spill data are reported, processed, and analyzed to facilitate data analysis. (3) Streamlined data management system should be collaborative among several agencies with complementary reporting jurisdictions to eliminate redundant and misleading data. (4) DMR should collect and analyze data to determine root causes of pipeline leaks, then continually refine regulations that address root cause determinations. (3)

13 ND should consider regulations on pipeline material selections, as has been done in other oil-producing states. (6) Installation crews should be thoroughly trained in all manufacturerprescribed installation procedures and be contractually bound to use those procedures. Independent inspectors should be responsible for ensuring that manufacturer specifications are precisely followed. (10)

14 DMR should consider requiring prior notice of intent to install liquid gathering pipelines. (8) HDD may be the most appropriate construction method near wetlands to reduce surface disturbances. Other measures may be warranted to ensure the impact to these areas are minimized in the case of a leak. (13) ND may consider construction standards currently required for transmission pipelines. (14) o o Third party inspectors would be responsible for ensuring compliance with state construction standards. State inspectors would verify that 3 rd -party inspectors maintain adequate oversight of the project.

15 ND should consider regulations on maintenance and corrosion control best practices. (7) DMR should consider requiring assurance of hydrostatic testing according to manufacturer recommendations on all newly installed or newly repaired liquid gathering pipeline segments. (15)

16 DMR should examine a potential role in the implementation and enforcement of a Pipeline Safety Management System for operators, modeled after API RP (19) The state, in cooperation with operators and vendors, could investigate alternate gathering system design features or unit operations that would enable pressurized and/or more consistent flow conditions, thus enabling improved leak detection system performance and accuracy. (20) Establish a regulatory environment that facilitates transition of pipelines from gathering to transmission, which would promote gathering system design and operation that provides the best possible performance.

17 Conclusion Better installations, more thorough 3 rd party inspections, and increased facilitation of learning from the past incidents will do more to prevent future gathering pipeline leaks than any available leak detection system. Phase I of this project (the study) provides information that allows ND DMR and industry to move quickly on actions they can take now to decrease spills and leaks. Phase II of this project (the demonstration) will provide information on the performance of those technologies with greatest potential to lessen the severity of future spills and leaks.

18 Blueprints Modeling the Pipeline Program after other Oil and Gas Division regulatory programs. Program Goal: Model the pipeline program after NDIC s current approach to oil and gas regulation. Make it an outgrowth of our approach to regulation, enforcement, and inspection.

19 Foundation HB 1333 (created section ) HB 1358 (created section ) EERC Study Structure Regulations Rulemaking (amendments to NDAC ) Current 2016 Rulemaking (amending existing rule) o Rule and regulations act as the external frame or structure of the building.

20 Facade Influenced by the statutes and regulations (i.e. the facades designed based on the building s structure and foundation). The Statutes and Regulations will control the regulatory interpretation, future policies and guidelines, enforcement, and inspection protocol.

21 Program Goal: Near-term goal is to develop amendments to existing rules and create new regulations that are necessary, cost-effective, feasible.

22 Legislation : 2013 HB HB 1358 CFR and PHMSA EERC Study Pipeline Rules Industry Standards Other States, Canadian Provinces, PSC Oil and Gas Division Regulatory expertise

23 Bonding Prior Notification All new construction Prior to pressure testing Before any repair or replacement Installation Properly trained construction crews in all manufacturer-prescribed installation procedures. Proper handling, backfilling, and minimum cover depth. HDD environmentally sensitive areas Right-of-way Reclamation Third-Party Independent Inspectors Responsible for ensuring the pipeline is installed as prescribed by the manufactures specifications are precisely followed. Above ground associated facilities Leak Detection and Monitoring Spill Response

24 February 16, 2016 Propose Rules to the Industrial Commission request approval to proceed with rulemaking. Public Hearing TBD Comment period TBD Administrative Rule adoption process is approximately a 8-10 month process. Pipeline rules to become effective January 1, In the Meantime. Hiring Pipeline Staff Field Inspectors and Database Administrator Developing a Pipeline Program Data Management System. Make our presences known.

25 Bismarck Office: Program Supervisor, Adm. Assistant, GIS, and Database Total Pipeline Program staff = 10 full time employees Pipeline Inspectors = 6 Engineering Technicians Field Inspectors

26 1) Improve underground gathering pipeline safety and integrity; Safe transportation of fluids. 2) Near-term goal is to develop amendments to existing rules and create new regulations that are necessary, cost-effective, feasible. o Which will in-turn influence the programs long-term goals. 3) Model the pipeline program after NDIC s current approach to oil and gas regulation. Make it an outgrowth of our approach to regulation, enforcement, and inspection. o I am looking for what translates from what we are already doing and have been doing for some time versus what needs to be created. (e.g. database module, inspection philosophy) 4) MAKE A DIFFERENCE o Reduce the number of small spills and try to eliminate the large spills through proper installation, monitoring and leak detection, and effective spill response.

27 Design Material Selection Construction Installation Inspection Abandonment Gathering Transportation Operation Operating Conditions Performance Safety Maintenance Regulation Best Practices Industry Standards Integrity Spill Prevention Corrosion Control Monitoring Leak Detection Data Sharing Spill Reporting Pipeline Repair Failure Analysis Spill Response