GOMR OCS Subsea Pipelines Regulatory...
Transcript of GOMR OCS Subsea Pipelines Regulatory...
GOMR OCS Subsea Pipelines
Regulatory Perspectives Pipeline Section, Regional Field Operations
Gulf of Mexico Region
Chief, Angie D. Gobert
Overview
Governing Regulations & Guidance Documents
GOMR Pipeline Statistics
Regulatory Challenges
Ongoing and Upcoming Research Projects
On the Horizon
Gulf of Mexico Region
Regulating OCS Pipelines
GOMR Pipeline Statistics
GOMR Pipeline (PL)
Infrastructure (as of 5/4/2017)
3,484 (17,809 mi/~28,661km) Active PL Segments
283 (358 mi/~455km) Proposed PL Installations
762 (2,057 mi/~1226km) Decommissioned PLs
354 (1,737 mi/~570km) Proposed PL Decom’s
692 (1,652 mi/~1113km) Out of Service Pipelines
Gulf of Mexico Region
Regulating OCS Pipelines
Governing Regulations and Guidance Documents
BSEE Regulations, NTL’s, and
LTL governing OCS Pipelines
30 CFR 250
Subpart J: Pipelines and Pipeline Rights-of-way
Subpart A: General
Departures
Alternate compliance
Definitions
Documents incorporated by reference
Inspection regulations
Subpart B: Plans and Information
Subpart I: Platforms and structures
Subpart Q: Decommissioning Activities
Notice to Lessees 2007-G14
Pipeline Risers Subject to the Platform Verification Program
Notice to Lessees 2009-G28
Guidance on preparing alternate compliance and departure requests from Subpart J
Letter to Lessees, April 18, 1991
Provide clarification, description, and interpretation with regard to pipeline requirements
Subpart J
Out of Date Standards
API RP 2RIM Phase 1
BSEE is member of Riser Integrity Management (RIM)
task group
Submitted for Ballot by Q2-2017
Coordinated with API RP 2FSIM and 2MIM
(Floating Systems/Mooring)
Focus
Align Philosophy & Reference Framework
Capture priority IM needs
Create Recommended Practice Document
Feedback Loop to Design Documents:
API Standard 2RD; API Spec 17J
API RP 2RIM Phase 2
Starting immediately following Phase 1
Specific IM guidance for different riser types by refining
both sides of Hazard Bowtie (Preventative and
Mitigation)
Feedback Loop to Design Documents:
API Standard 2RD; API Spec 17J
Gulf of Mexico Region
Regulating OCS Pipelines
Regulatory Challenges
Regulation Challenges
Regulations require pipeline routes to be checked once a
month requires company cooperation. Regulations lack
guidelines for pipeline inspections.
Regulations do not address integrity management.
Companies are currently employing their own
independent form of integrity management.
Regulations do not address deep water pipeline specific
issues.
Decommissioning Challenges
Decommissioning in-place in Sand Sediment Resource
Areas (SSRAs)
Requires concurrence from BOEM
Decommissioning in-place in Anchorage & Shipping
Fairways
Requires concurrence from USCOE
Decommissioning pipelines without pigging
Decommissioning plugged pipelines
Gulf of Mexico Region
Regulating OCS Pipelines
Ongoing and Upcoming Research Projects
Riser Life Extension
Ongoing investigation of procedures regarding
qualification of riser life extension
Achieve industry consensus on analytical parameters for
fatigue assessment used for life extension.
2H has launched a JIP for Steel Catenary Risers (SCRs)
named STREAM (STeel Riser Enhanced Analytics using
Measurements) aimed to provide a measurement based
foundation for SCR modelling for accurate fatigue
assessment. Full scale field data from over six (6) deep
water riser systems have been aggregated from JIP
participants.
Riser Life Extension
Anadarko's King Risers (Marling TLP at VK 915), lift gas
lines within SCRs and SCR PIP Segments are currently
under review
Flexible Pipeline Segments 13145 and 13146 - CVA
Nomination and Plan for Life Extension received and is
currently under review
Other Ongoing and Upcoming
Research Projects
Incorporating an internal policy of accepting ASME B31G
as part of integrity management plan ongoing.
Deepwater Pipeline Maintenance and Decommissioning
Study
Gulf of Mexico Region
Regulating OCS Pipelines
On the Horizon
ePermitting
Streamline permitting/reviewer coordination.
User friendly and more efficient.
Development of the high level requirements completed
November, 2016.
Design phase initiated by mid-November, 2016.
Internal beta testing has begun as of mid-2017.
Other On the Horizon Projects
Pipeline Integrity Management & Riser Assessment
study(ies) FY 2017
Composite Wrap Repair Study (In Progress) Completion
Date September 2017
Deep water pipeline maintenance and decommissioning
Subpart J TBD
Subsea Pipelines
Discussion Considerations
What is the most important issue to you that
needs to be addressing
Who is best positioned to address the issue
Is there a standard that addresses the issue
What methods or techniques would you use
What information would you need
What tasks are required for solving the issue
What is the time line for solving the issue
What goals are achieved by solving the issue
Subsea Pipelines
Discussion Consideration
What is the most important issue to you that
needs to be addressing
Corrosion inspection methods, protocols,
maintenance, resulting repairs & pipeline integrity
management.
Subsea Pipelines
Discussion Consideration
Who is best positioned to address the issue
Industry, Standard Groups, and Government
A collaborative effort
Subsea Pipelines
Discussion Consideration
Is there a standard that addresses the issue
B31 G for wall thinning caused by pitting.
Subsea Pipelines
Discussion Consideration
What methods or techniques would you use
The applications of B31G should be evaluated and
the most prudent and validated approach or
application should be adopted.
Subsea Pipelines
Discussion Consideration
What tasks are required for solving the issue
A study group of industry SMEs, API members,
and government to develop a reliability report on
the various B31G methods.
Subsea Pipelines
Discussion Consideration
What is the time line for solving the issue
The sooner the better
Subsea Pipelines
Discussion Consideration
What goals are achieved by solving the issue
Determining the MAOP thereby maintaining a safe
operating pressure and the integrity of the pipeline.
Website: www.bsee.gov
@BSEEgov
BSEEgov
Bureau of Safety and
Environmental Enforcement
Summary
Integrity management versus inspections
We are concerned about the integrity, not the
inspection itself
Plugged pipelines
Concern of hydrocarbons in the pipeline over time
with the potential of corrosion leading to hc release
Innovative techniques to be expored
Records retention
Subpart J reference 1005 Pipeline inspection records
shall be retained for two years
Summary
Reference to latest revision of standards
International codes may reference “latest edition”
US regs bound by xx standards acts
Equivalent compliance rather than alternative
“innovation”
Guidance on lifetime extension
Revalidating international standards