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Posts Tagged ‘PHMSA’

New PHMSA (DOT) regulation

At the behest of Congress, coastal areas and beaches are now designated as Unusually Sensitive Areas (USAs). Given that any offshore liquids pipeline has the potential to affect coastal waters or beaches, the rule would seem to require that all such pipelines be included in Integrity Management Programs, which are mandatory for pipelines that could affect USAs. (The IMP requirements would almost certainly apply to all DOT regulated offshore pipelines. Their applicability to DOI/producer pipelines is less certain. Of course, very little is clear and consistent in US offshore pipeline regulation.)

As one would expect, the recent Huntington Beach pipeline spill is among the incidents cited in the justification for this regulation. More surprisingly, the Santa Barbara well blowout was also cited. This incident occurred 53 years ago, was the result of a reckless drilling program, and had nothing to do with production operations or pipelines.

As noted in a recent BOE post, the regulatory regime for offshore pipelines is badly in need of overhaul. DOT and DOI, with inconsistent jurisdictional boundaries, regulations, and approaches, have primary responsibility and multiple regulatory entities have roles.

Lastly, PHMSA seems to have inadvertently posted a highlighted copy of the new regulation. Nothing at all scandalous (looks like someone was highlighting potential talking points), but possibly amusing to other regulation nerds. 😃

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BSEE data indicate that the operator of the Beta Unit facilities (Platforms Ellen, Elly, and Eureka, and the associated pipelines) had a good compliance and safety record.

  • Since 1/1/2015 Beta facilities were inspected 262 times and 49 Incidents of Non-Compliance (INCs) were issued.
  • The ratio of 0.19 INCs/inspection was better than the average for the Pacific Region (0.29 INCs/inspection).
  • No facility shut-in orders were issued during that period.
  • BSEE assesses civil penalties for violations that constitute a serious threat to safety or the environment. Since 1/1/2015, Beta has not been assessed any civil penalties.
  • BSEE incident data are badly out-of-date (no data posted for 2020 or 2021), but the most recent incidents at the Beta Unit facilities were 2 minor injuries (no lost time) in 2019, a small dryer fire in 2018, a minor injury (no lost time) in 2017, and a lost time injury (fall) in 2016.
  • BSEE’s oil spill data are even more out-of-date (no data posted since 2013) so it is difficult to assess Beta’s performance in that category.

With regard to the Huntington Beach pipeline spill, the evidence to date seems to confirm that the pipeline damage was caused by anchor dragging. Beta’s response to the PHMSA preliminary finding on their delayed response to the low pressure alarm (see previous post) will be of great interest. Alarm issues are not always straightforward. PHMSA’s 12-page order was issued on Monday (10/4), only 2 days after the spill was reported. The investigation will no doubt carefully consider the pressure and alarm history for the pipeline, data for 10/1 and 10/2, and input from those working in the control room.

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Per PHMSA:

  • At approximately 02:30 PDT (05:30 Eastern Daylight Time (EDT)) on October 2, 2021, Beta Offshore’s control room personnel received a low-pressure alarm on the San Pedro Bay Pipeline, indicating a possible failure.
  • Beta Offshore reported the San Pedro Bay Pipeline was shut down at approximately 06:01 PDT (09:01 EDT) on October 2, 2021—over three hours later.

Comment: Very interesting finding. Good to learn that the pipeline pressures were being monitored. Need to see the pressure history for the pipeline and hear from the crew before reaching any conclusions regarding the conduct of the operator.

Also note that PHMSA is estimating that the spill volume was 700 barrels, far less than the 3000+ bbl maximum estimate. Further, a footnote in the PHMSA letter reports an updated company estimate of 588 barrels. I’m assuming that the refined estimate was based on meter differentials. These lower estimates are more in line with the oil recover data that have been provided and the visual images of the slick.

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