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


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



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Out of Date Standards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



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



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



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


Who is best positioned to address the issue

Industry, Standard Groups, and Government

A collaborative effort

Subsea Pipelines


Is there a standard that addresses the issue

B31 G for wall thinning caused by pitting.

Subsea Pipelines


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


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


What is the time line for solving the issue

The sooner the better

Subsea Pipelines


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

http://www.bsee.gov/

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