Managing Environmental Compliance: A Study of Expansion, Replacement and Integrity Projects

摘要

Environmental compliance for pipeline activities is subject to varying degrees of regulatory over-sight. Case studies are presented that compare and contrast the strict and closely regulatedmandates of mainline expansion with the rather subjective and often self-regulated activities typ-ical of operations and maintenance efforts including pipeline integrity projects. These exampleswill demonstrate why the type of activity and project location are often the defining factors whenassessing the applicable regulatory framework for a given project. Often when undertaking op-erations and maintenance activities pipeline operators must satisfy multiple regulatory agenciesand thereby manage specific compliance issues by activity or agency based upon a subjectiveinterpretation of available regulatory guidance. Therefore, the environmental staff at pipelinecompanies must be well versed in a wide range of environmental rules and regulations to dis-criminate between regulated and unregulated activities and prepare environmental compliancemeasures appropriately. By example it is demonstrated why project size and cost are less signifi-cant factors when evaluating compliance issues. A minor interconnect project may require a fullFERC filing and proceedings, whereas a large-scale coating repair project may be relatively un-regulated and is not subject to FERC oversight. However, a seemingly unrelated issue, such asworkspace requirements can ultimately determine the compliance measures mandated by agen-cies. Case studies are presented to highlight these points while demonstrating some of the variousregulatory scenarios for common pipeline activities including expansion, FERC 2.55(b) replace-ment, FERC Blanket Certificate replacement and pipeline integrity projects.