Oil Spill Prevention Regulations:
Suggestions for Improvement
Alaska Department of Environmental
Conservation
Spill Prevention and Response Division
Industry Preparedness Program
Craig Wilson
May 3, 2005
Contingency Plan Regulations
Project (CPR)
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Multi-phase, multi-year project to
comprehensively review and update the oil
discharge prevention and contingency plan
regulations in 18 AAC 75
Phase 1 completed May 2004
Currently in Phase 2
Goals of the Phase 2
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Make the regulations efficient and enhance clarity.
The regulations should “fill in the gaps” where other
requirements are either non-existent or inadequate.
The regulations should complement other requirements
and form a comprehensive, coherent regulatory regime.
Currency of standards.
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Present regulations last revised early 1990s.
Predictability in enforcement.
Schedule
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July 2004 – Letter sent to all plan holders
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Asked five basic questions
Solicited comments, suggestions
November 2004 – Public Workshop, Anchorage
April 1, 2005 – Discussion paper issued
July 1, 2005 – End of informal comment period
Fall, 2005 – Formal comment period on proposed
rulemaking
February 2006 – New regulations adopted
Discussion Paper
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Published April 1, 2005, available on website
Designed to stimulate discussion
Provides a target to shoot at for comments
Nothing is fixed in stone at this point
ADEC will be accepting informal comments on
the paper until July 1, 2005
Summary of Considered Changes
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Update references to third party standards and delete 18 AAC 75.090.
Increase prevention training and documentation requirements.
Preventative booming during vessel transfers for combustible liquids and unsegregated ballast
water.
Performance standard for lightering equipment for laden oil tank vessels and oil barges.
Impermeable wellhead sumps for exploration and production wells and artificial islands.
Leak detection requirements for crude oil transmission pipelines from 1% of daily throughput
to .5% of daily throughput and add computational pipeline monitoring (CPM) system
regulations.
Shop-fabricated tanks under 50,000 gallon capacity must meet UL142 construction and STI
SP001-03 inspection standards. Non-standard taken out of service by 2015.
Vaulted, self-diked, and double-walled tanks are defined in regulation, and exempted from
some secondary containment requirements.
Adopt the NACE standard for cathodic protection for both tanks and piping.
Adopt ASME B31.3 and B31.4 design standards and API 570 inspection standards for facility
piping.
Define “facility oil piping”.
Revise the prevention plan portion of the c-plan, include annual self-certification requirement.
Approval criteria for spill prevention training and the prevention plan portion of the c-plan.
What Isn’t Included
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Tanker Escort System
Homeland Security / Terrorism Issues
Pipeline valves / Federal pipeline standards
Risk-based inspection under API 653
Refined product pipelines
Gathering lines
Process flow lines
?
Alaska Administrative Procedures
Act (APA)
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Formal regulatory
process governed by
statute
Governs process, format,
style, and grammar
Takes a minimum of 90
– 120 days to complete if
no contentious issues
18 AAC 75, Article 1 – Oil Pollution
Prevention
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Major changes listed in discussion paper
Separating out spill prevention training
 Protective booming for combustible liquid transfers
 .5% leak detection standard for crude oil
transmission pipelines
 CPM for pipelines
 UL142 standard for tank construction
 STI inspection standard
 Piping standards (API 570, ASME B31.3, B31.4)
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Prevention Training
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Moved into its own section & expanded
Listing of job descriptions and training level
needed
Maintain records for 5 years
Oil Transfers from Vessels
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Protective booming for transfers of combustible liquids
and oily ballast water
Performance standard for lightering tank vessels and oil
barges
Exploration & Production Facilities
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Changed “offshore platform” to “marine structure”
Impermeable wellhead sumps for new wells onshore
and on artificial islands
Pipelines
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Leak detection
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Changed from 1% to .5% of
daily throughput
Computational Pipeline
Monitoring (CPM)
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API 1130 Standard
Aboveground Storage Tanks &
Secondary Containment
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Non-adoption of API 653 riskbased inspection
UL 142 standard for tanks less than
50,000 gallon capacity
STI SP001-03 inspection standard
for shop fabricated tanks
NACE 0193-2001 cathodic
protection standard
Recognition of double-walled and
self-diked tank designs
Facility Piping Definition
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“facility oil piping” means piping and associated fittings originating or
terminating at an oil storage tank regulated under 18 AAC 75.065 or an
exploration or production well, located within the boundaries of an oil
terminal, crude oil transmission pipeline, exploration or production facility,
including all valves, elbows, joints, flanges, pumps, and flexible connectors, up
to the:
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(A) Union of the piping with a fuel dispensing system;
(B) Marine header;
(C) Fill cap or fill valve;
(D) Forwarding pump used to transfer oil between facilities, between adjacent
pump stations, or between a pressure pump station and a terminal or breakout
tank;
(E) First flange or connection within the loading rack containment area; or
(F) First choke or valve inside a manifold building, or if a manifold building is not
present at the well pad, the first choke or valve inside a gathering center or flow
station
Facility Piping
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ASME B31.3 & B31.4
design standards
API 570 inspection
standards
NACE RP0169-2002
standard for cathodic
protection
18 AAC 75, Article 4 – Oil Discharge
Prevention & Contingency Plans
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Revision of Prevention Plan contents
Direct linkage to Article 1 requirements
 Annual prevention measures review & certification
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Response Planning Standard documentation
requirement
Approval criteria for spill prevention training
and prevention plan contents
18 AAC 75, Article 9 - Definitions
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Where possible, definitions were moved into the
appropriate sections.
New definitions
Cathodic protection
 Corrosion terms
 Placed in service/removed from service
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For More Information & Updates
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Website - http://www.dec.state.ak.us/spar/ipp/cpr.htm
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Automated email list server
Email – Craig_Wilson@dec.state.ak.us
Craig Wilson
Spill Prevention & Response Division
Alaska Department of Environmental Conservation
410 Willoughby Ave., Suite 303
Juneau, AK 99801
voice: (907) 465-5204
fax: (907) 465-5245