Sam Fletcher
OGJ Online Senior Editor
More stringent safety requirements in �high-consequence� areas may send US pipeline companies scrambling for outside expertise that they don�t have in house, industry officials said Monday.
New Department of Transportation rules require operators of liquid pipelines by the end of this year to identify which segments of their systems impact high-consequence areas with high population density or that are near water resources or other environmentally sensitive regions. But government officials must define those terms more clearly in order for pipelines to comply, say industry representatives.
The DOT�s Office of Pipeline Safety (OPS) recently issued a requirement that liquid pipeline companies submit for its inspection their written integrity programs for such pipeline segments by Mar. 31, 2002. OPS officials are drafting similar rules for the natural gas pipeline industry.
Meanwhile, the Interstate Natural Gas Association of America (INGAA) is working with regulators to develop methodologies for exercising and measuring integrity management, including clarification of technical issues and terms.
For example, industry officials said, corrosion issues do not apply uniformly to both liquid and gas pipelines.
Outside consultants
Pipeline companies without the necessary in-house resources will be forced to rely on outside consultants, said Joe Killins, manager of the new pipeline integrity management team formed by Paragon Engineering Services Inc. in Houston to comply with the new inspection and maintenance requirements.
�Because of public sensitivity over recent incidents, extensions to the proposed deadlines are not likely to occur,� he said. �We can study a system, come up with a plan and put together a compliance program very quickly.�
Paragon has worked with Battelle Laboratories, the National Transportation Safety Board, OPS, and INGAA on those issues, Killins said.
Focus areas include corrosion, risk analysis, smart pigs, mapping, pipeline repairs and modifications, hydrotests of pipelines, operator testing, project management or coordination, emergency response planning, and leak detection and monitoring, as well as assessing and mitigating environmental impact.
EPA influences
Other recent actions by the US Environmental Protection Agency might also have a major impact on the pipeline industry, say other analysts.
In late November, the US Justice Department, on behalf of the EPA, filed suit on behalf of the US Environmental Protection Agency against Atlanta-based Colonial Pipeline Co. in a move that could drastically extend the 5-year statute of limitation on violations of the Clean Water Act.
Justice attorneys claim Colonial pipeline demonstrated a "pattern and practice" of spills totaling some 3 million gal of oil and petroleum products from its 5,349-mile pipeline over the last 20 years. The pipeline "isn't being cared for in the way that prevailing standards in the law require," claimed a Justice spokeswoman (OGJ Online, Dec. 1, 2000).
Earlier that same month, EPA officials approved an unprecedented safety and mitigation program that industry officials claim will add another 6 months of work and tens of millions of dollars to the cost of a pipeline project to carry refined products across Texas from Houston to El Paso.
That deal brings the Longhorn Partners Pipeline LP project closer to completion. Its cost was estimated at $399 million when the project began in 1995.
The action came on instructions from the White House Council on Environmental Quality in September after Longhorn Partners agreed to 40 steps to reduce ecological dangers along the pipeline route. It includes "extraordinary safety and mitigation measures that have not been required on any pipeline in the country" and which meet or exceed any future pipeline safety requirements under consideration in congress, said government officials (OGJ Online, Nov. 8, 2000).
Meanwhile, industry officials wonder if this may set new thresholds for future pipeline safety.
Pipeline firsts
The Longhorn pipeline will be the first to ban products that contain methyl tertiary butyl ether or similar additives�tertiary amyl methyl ether, ethyl tertiary butyl ether, di-isopropyl ether�in greater than trace amounts, EPA officials said.
A major part of the 700-mile pipeline is a 450-mile section from Houston to Crane in the Permian basin that was built in the 1950s to carry West Texas crude to Gulf Coast refineries. Longhorn Partners acquired that pipeline in 1995, with the aim of reversing its flow to carry gasoline and other refined products from Houston-area refineries to markets in West Texas, New Mexico, and Arizona.
As part of the environmental agreement, Longhorn Partners will replace 19 miles of that 1950s-vintage pipe over a section of the Edwards Aquifer near Austin with thicker-walled pipe. The replacement pipe is to be buried at a depth to reduce the potential for third-party damage, with a concrete barrier over it for additional protection.
The Edwards Aquifer in central Texas is one of the most prolific artesian aquifers on the globe. It is the sole source of drinking water for some 1.5 million people, including the cities of San Antonio and Austin, the Texas capital.
Protection, observation measures
The partners also are required to design and develop a trench across that section of the aquifer's recharge and contributing zones to capture any accidental release. They also must install a system across the recharge and nearby contributing zones that is capable of detecting "even very small leaks" within 12-20 minutes of initial discharge.
Pipeline pump stations are to be inspected every 2� days in environmentally sensitive and highly populated areas. Remote cameras are to be installed to monitor all pump stations prior to start up.
Under the environmental agreement, Longhorn must perform semiannual pipe-to-soil potential surveys in sensitive areas along the pipeline�twice as often as currently required by Department of Transportation regulations, officials said.
The partnership also must do aerial and ground surveillance of the pipeline every day in the Edwards Aquifer area; every 2� days in other environmentally sensitive and highly populated areas; and weekly in all other regions. All of those schedules also are more frequent than now required by law, officials said.
Pipeline marker signs in both English and Spanish must be posted at more frequent intervals along the pipeline route than now specified by industry standards, including at all above-ground facilities and on each side of public road, water and railroad crossings.
In addition, Longhorn Pipeline is required to cease operation during "extreme flood conditions" at its Pedernales River crossing. Longhorn Partners must pay an outside contractor to test water quality at 12 locations near to stream crossings and arrange alternate water supplies for municipalities and private water-well owners "that have sensitive groundwater resources" along the pipeline route.
Opponents of the proposed pipeline filed a class-action suit that resulted in a federal judge issuing a temporary injunction against the pipeline. In 1999, parties to that original suit agreed to a voluntary environmental assessment jointly directed by EPA and DOT. As part of that study, an outside contractor analyzed 8,100 segments of the pipeline, checking for safety along its entire length.
A draft report of that assessment was released in October 1999 with a preliminary finding of no significant impact on the environment.
If the federal judge grants final approval, Longhorn Partners expects to open the pipeline by mid-2001.
Colonial issues
The federal lawsuit against Colonial charges that pipeline corrosion, mechanical damage, and operator error resulted in numerous spills by the pipeline in Louisiana, Alabama, Georgia, Tennessee, South Carolina, North Carolina, Maryland, Virginia, and New Jersey.
The lawsuit filed in US District Court in Atlanta seeks a court order that would force Colonial to cover exposed and shallow pipe; inspect for and repair corrosion and cracks promptly and in accordance with industry standards; and to upgrade and maintain its cathodic protection system and leak detection strategy and system.
Justice also is seeking significant civil penalties from Colonial Pipeline under the Clean Water Act. The act authorizes civil penalties of up to $25,000/day of violation prior to January 1997, and $27,500/day for each day thereafter, or $1,000/bbl of oil spilled or $3,000/bbl in the case of "gross negligence."
Colonial Pipeline spokesman Steve Baker said the company was "disappointed" with the lawsuit, adding that Colonial has been working "very hard" with Justice to reach a settlement. Baker added that Colonial paid more than $13.5 million in damages to the federal and state governments for the Reedy River spill. In that incident, 960,000 gal of diesel fuel spilled in South Carolina (OGJ, Mar. 8, 1999, p. 29).
Since the Reedy River spill, Baker said, Colonial has changed its top management and made safety and maintenance the "absolute number one priority," cutting its operator error incidents 80% over the past 2 years. Baker described the causes of past spills as a combination of operator error and pipeline failure.
During a 5-year probationary period following the Reedy River incident, Colonial was required to develop and implement an environmental compliance program to prevent and detect problems on its entire system. The court also required Colonial to make presentations to national pipeline associations regarding pipelines' Clean Water Act obligations.
