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Subpart J Out of Date Standards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 Focus (Floating Systems/Mooring) 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