Flow Line Regulations 18 AAC 75.047 Alaska Department of Environmental Conservation Spill Prevention and Response Division Industry Preparedness Program

What is a flow line? 18 AAC 75.990(173) "flow line" (A) means piping and associated fittings, including all valves, elbows, joints, flanges, pumps, and flexible connectors, (i) containing liquid oil; (ii) located at a production facility; and (iii) that is installed or used for the purpose of transporting oil between a well pad or marine structure used for oil production and the interconnection point with a transmission pipeline; and (B) includes all piping between interconnections, including multi-phase lines and process piping, except (i) facility oil piping; and (ii) transmission pipelines; In plain English, a flow line carries multi-phase (oil/water/gas) to or from a well head manifold or a processing center.

Crude Oil Transmission Pipeline Protective coating & CP What isn’t a flow line? Crude Oil Transmission Pipeline Flow Line Facility Oil Piping Typical size (diameter) 6 – 48 inches 4 – 30 inches <8 inches Pipe Contents Crude Oil Multi-phase Oil Oil ADEC Regulation 18 AAC 75.055 18 AAC 75.047 18 AAC 75.080 Leak Detection Yes (1% daily volume) No Design Standard Yes ASME B31.4, B31.8 Yes ASME B31.3, B31.4, B31.8 Cathodic Protection Standard Yes Yes NACE RP0169, API 570 Corrosion Control Standard ASMEB31.4, NACE RP0169 Protective coating & CP Inspection Standard API 570 Maintenance Standard ASME B31.4, API 570 These are state regulations, additional federal regulations apply to COTPs

How are flow lines regulated? Design & construction standards Corrosion monitoring & control Preventative maintenance Line markers Removal from service requirements Line supports Compliance documentation & recordkeeping

Design & construction standards ASME B31 series industry standards for design and construction of pipe: ASME B31.4, Pipeline Transportation Systems for Liquid Hydrocarbons and Other Liquids ASME B31.8, Gas Transmission and Distribution Piping Systems Other “equivalent and nationally recognized standard” Design & construction standards become effective 31 December 2008 (2 year phase-in) It is assumed that most operators will follow B31.4. B31.8 is a more stringent standard which may be useful to operators who have plans for conversion to gas production or who want a higher standard. 3rd option is a back door to allow for future changes.

Corrosion monitoring & control Industry standards ASME B31.4, Chapter VIII NACE RP0169-2002 for external corrosion control on submerged or buried lines External corrosion control Protective coatings on aboveground lines or corrosion-resistant material Internal corrosion control program Pigging, inhibitors, biocides, coatings, linings, etc. Corrosion monitoring & control requirements become effective 31 December 2007 (1 year phase-in)

Preventative maintenance Choice – either: Use a bundled pipe with an interstitial leak detection system, or Have a preventative maintenance system in place Preventative maintenance system Consistent with ASME or API standards Effective 31 December 2007 (1 year phase-in) The first option is for bundled lines, where a comprehensive preventative maintenance system is problematic, but where an effective leak detection system and secondary containment is viable.

Preventative maintenance program standards Submerged lines ASME B31.4, Chapters VII through IX Buried lines ASME B31.4, Chapters VII & VIII Aboveground lines API 570 (except Section 8) and All preventative maintenance programs must have procedures for management of change

Line markers, removal from service, and pipe supports One mile intervals and at each road crossing Effective 31 December 2007 (1 year phase-in) Removal from service Pig, drain, or blow pipe to remove oil Effective 31 December 2006 (now) Pipe supports ASME B31.4, Paragraph 421

Documentation / Recordkeeping Documentation of measures taken to comply with 18 AAC 75.047 Corrosion control Preventative maintenance Maintain records for minimum of five years Records must be available to ADEC upon request

Other changes to 18 AAC 75, Article 1 that affect North Slope operations Increased prevention training and documentation requirements Revised regulations for aboveground oil storage tanks field-constructed oil storage tanks shop-fabricated oil storage tanks Revised regulations for facility piping

Prevention training Moved into its own section and expanded Personnel that inspect, maintain, operate oil storage and transfer equipment must be trained regarding company and state spill prevention measures Job descriptions and training level needed Keep training records for 5 years

Aboveground storage tanks Two types defined Field-constructed storage tank Constructed to API 650, API 12B, 12C, 12D, 12E, 12F, or 12P Inspected to API 653 or API 12R1 Shop-fabricated storage tank Constructed to UL 142 or similar standard Inspected to API 653 or STI SP001

Facility oil piping New definition: Piping and associated fittings originating from or terminating at a regulated oil storage tank or an exploration or production well Three classes of facility oil piping, based on installation date: Before May 14, 1992 – no construction standard applies May 14, 1992 thru 2008 – protective coating and cathodic protection, all welded 2009 or later – ASME B31.3, B31.4, or B31.8, or equivalent standard; cathodic protection per NACE standard Inspection consistent with API 570 inspection standard by 2008

Effective Dates Regulations covering design and construction – go into effect in 2009 Regulations covering operations and maintenance – go into effect in 2008 Remaining regulations - December 30, 2006

Questions? Craig Wilson Industry Preparedness Program Spill Prevention and Response Division Alaska Department of Environmental Conservation www.dec.state.ak.us/spar/ipp