The Alaska Department of Environmental Conservation is working toward initiating a Cook Inlet pipeline review and risk assessment as part of its larger review of the Alyeska and North Slope pipelines.
The Cook Inlet Regional Citizens Advisory Council called for DEC to perform a comprehensive review of inlet pipelines during a meeting of its Preventative Response and Operations Safety Committee on Aug. 24.
CIRCAC first identified a need for such a review over a year ago in a report that gave an overview of pipeline regulatory requirements. The report pointed out the regulatory confusion that comes from the lack of a single agency coordinating the design, construction, maintenance, operation and spill response plans for Cook Inlet pipelines. It also indicated that Cook Inlet pipelines are nearing the end of their projected life spans.
DEC agrees with CIRCAC that a review is needed and has been working toward one for the last year, according to Larry Dietrick, with DEC's Division of Spill Prevention and Response. "Conceptually, industry, CIRCAC and everybody else are on notice that we want to go down this path," Dietrick said. "It just takes a lot of work to get the details straightened out."
In order for a comprehensive review and risk assessment of the Cook Inlet pipeline infrastructure to be done, DEC needs to work out an agreement among all the parties involved, including the oil industry, CIRCAC and regulatory agencies, as to how the review is carried out. There needs to be a consensus on the scope of the review, how to go about it and what it will cost, said Dietrick.
That is what DEC is working on now -- putting together a plan that addresses the concerns of all the parties involved and that everyone agrees on.
In order to complete that plan DEC is attempting to determine the jurisdictional requirements the pipelines are already under, by both state and federal agencies and the oil industry.
The oil industry already has regulations in place for its pipeline operations. DEC has met with Unocal, for instance, to get information on what the company has been doing for risk assessments.
"It's not like we're without a risk assessment," Dietrick said. "The industry has already done a fair amount. One of the concerns here is that we not duplicate what they've done and waste money."
DEC is not the only government agency with the jurisdiction to impose regulations on pipeline operations. The federal Environ-mental Protection Agency and Department of Transportation , for instance, also have the authority to impose regulations. According to Dietrick, the Department of Transportation is in the process of issuing rule-making regulations on carrying out pipeline assessments. Those regulations will include a lot of the requirements for doing a risk assessment that DEC, the oil industry and CIRCAC favor, Dietrick said.
So in coming up with a plan for its review, DEC doesn't want to impose regulations that are already being imposed by other organizations.
"We're working with other agencies that have (pipeline assessment) requirements and finding out what new requirements will be coming in the future," Dietrick said. "We don't want to duplicate an assessment requirement that's already being covered. There's no point in recreating the wheel there. We need to integrate our assessment with theirs and cover the pieces that won't be performed under their requirements."
CIRCAC's report compared this overlapping and interconnected system of regulatory and agency involvement to a bowl of spaghetti, and noted that there is no clear delineation of regulatory authority for Cook Inlet pipelines.
It doesn't help matters that, according to Dietrick, DEC is working to straighten out this arrangement on a "time-available basis."
DEC intended to get funding to carry out all the front-end studies, like developing the scope of the review, sorting out the pipeline regulatory jurisdictions, evaluating current spill-prevention measures, surveying existing pipelines and coming up with what, if any, corrective actions need to be taken, as part of its fiscal year 2002 budget.
The Cook Inlet pipeline review is one part of the DEC's larger review of the Alyeska and North Slope pipelines. DEC submitted a proposal for $500,000 to cover the review for the 2002 fiscal year. Around $150,000 of that budget was proposed to cover the initial research for the Cook Inlet review. The proposal was rejected by the Legislature. Since DEC didn't get the money it had hoped for the Cook Inlet review, it is completing the background work with its normal budget and on a time-available basis.
"We do a review of these pipelines as part of our prevention and contingency plans review anyway," Dietrick said. "It's just when you approach them on a regional basis rather than an individual basis it takes on a whole new dimension. Instead of looking at one pipeline at a time we're looking at the whole of Cook Inlet. It's a huge chore, and we're running about as fast as we can."
Dietrick hopes DEC will complete its research, reach a consensus with the oil industry, CIRCAC and involved parties on the scope of the review, and put that into a proposal for how to go about the assessment during this fiscal year. That way it can submit a funding proposal for next year's fiscal budget with the initial review work already done, which may increase the chances of getting favorable legislative consideration, Dietrick said.
"It's no small thing to take on the entire infrastructure of Cook Inlet," Dietrick said. "But we'll get there. The industry's goal is to not spill oil, and that's the same goal as everybody else on the peninsula. People want to make sure the pipeline infrastructure is safe for another 20 years."
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