colorado’s new flowline rules
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COLORADO’S NEW FLOWLINE RULES
FEBRUARY 28, 2018
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COMPREHENSIVE RULEMAKING
20+ pages of new regulations 24 new/amended defined terms 22 new reports/registrations/notices 5 General Areas
– Registration– Pipeline Standards– Special Regulations for Valves– Integrity Management – Abandonment
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DEFINITIONS: RULE 100 SERIES
Defines various types of flowlines Distinguishes between on‐location and off‐location
pipelines Significant Definitions to Consider
– Crude Oil Transfer Line (COTL)– Flowline (FL)– Off Location Flowline (OLFL)– Produced Water Transfer System (PWTS)– Grade 1 Gas Leak
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REGISTRATION
All flowlines leaving an oil and gas facility must be registered
– New Lines: Constructed on/after May 1, 2018
– Existing Lines: Constructed before May 1, 2018
Builds off of the Flowline NTO submittals
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OLFL REGISTRATION: RULE 1101.a.
New Lines Register within 30 days of placing
line in‐service Requirements:
– Geodatabase– Layout Drawing– Bedding– Pipe Materials– Pipe Diameter– Fluid Type– MAOP/Tests– Description of start and end
Existing Lines Register by October 31, 2019
Requirements:
– All known info & data in newly constructed OLFL registration
– Lat/Long of Risers
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COTL/PWTS REGISTRATION: RULE 1101.c.
New Lines 10‐day preconstruction notification As‐Built specs must be submitted
within 30 days of placing line in‐service
Requirements:
Existing Lines Register by October 31, 2019
Requirements:
– All known info & data included in the As‐Built filing for new COTL/PWTS– Geodatabase
– Layout Drawing
– Bedding
– Fluids
– MAOP/Tests
– Pipe Description
– Depth
– Corrosion Protection
– Int. Mgmt. System
– Construction Method
– Leak Protection Plan
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OLFL/COTL/PWTS REGISTRATION
Must report any modifications to OLFL and COTL alignment within 30 days
Must report PWTS alignment changes by May 1st of each year for preceding year
After May 1, 2018, must record a document granting right of access or easement– May use a memorandum or notice – Must include legal description or map if contained in base
document– Must provide to surface owner upon request
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DOMESTIC TAP REGISTRATION: RULE 1101.b.
New Lines Register within 30 days of
installation Requirements:
– Lat/Long of connection points
– Notify tap owner of tap requirements
– Supply Odorant
Existing Lines
Known: Register by October 31, 2019
Unknown: Register within 30 days of discovery
Requirements:
– Lat/Long of connection points
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GAS GATHERING SYSTEM REGISTRATION: RULE 313B
Gas gathering systems, compressor stations, processing plants, or underground gas storage facilities must be registered– Within 30 days of placing into service– No later than October 31, 2019 for existing facilities– Registration Requirements
• Name and type of system• Location• Facility layout drawing• Topographic map of gathering system
Annual reporting for modifications, expansions and decommissioning
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PIPELINE STANDARDS: RULE 1102
New standards for flowlines and COTL– Design– Installation – Repair – Maintenance
Generally follow established third‐party standards Corresponding record‐keeping requirements One Call participation
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VALVE STANDARDS: RULE 1103
Annual isolation valve maintenance required– Function test– Maintain within manufacturers specs– Replace if not operable
Isolation valves must be installed in certain locations– At pump station, breakout tank, certain terrain features, and
waterbodies – Must retrofit existing lines by October 31, 2019
On‐location manifold, peripheral and process piping are exempt from maintenance and retrofitting
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VALVE STANDARDS: RULE 1103
Check valves or reverse flow device required
– Two or more wells produces through common flowline
– Install on each line leading from well
–Maintain in working order
– Operator must test at Directors request
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INTEGRITY MANAGEMENT: RULE 1104
Initial testing required– Newly installed or repaired segments prior to activating– Test to MAOP
Periodic testing during operations Operator must test at Directors request Various requirements for different lines
– Below Ground: Dump Lines, On‐location Flowlines, and OLFL/COTL– Above Ground: On‐location Flowlines
Note: flowlines and crude oil transfer lines active and subject to all requirements until properly abandoned
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INTEGRITY MANAGEMENT: RULE 1104
Audio, Visual and Olfactory (AVO)– Detects integrity failures through stressed vegetation or soil discoloration
Instrument Monitoring Method (IMM)– FLIR and other technologies
Operator must document the date and time of the survey, detection methodology and name of the employee conducting the survey
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INTEGRITY MANAGEMENT: RULE 1104
Below ground Dump Lines
– Annual static‐head test
–Monthly AVO
Above ground On‐location Flowlines
– Annual static‐head test
–Monthly AVO
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INTEGRITY MANAGEMENT: RULE 1104
Below ground On‐location Flowlines– Pressure test to MAOP every 3 years
– Smart pigging every 3 years• Must measure wall thickness and defects
• May require GPS capabilities
– Continuous pressure monitoring; or
– Annual AVO/IMM
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INTEGRITY MANAGEMENT: RULE 1104
OLFL and COTL– Annual pressure test to MAOP
– Continuous pressure monitoring
– Smart pigging every 3 years; or
– Annual IMM
Produced Water Flowlines Below ground
– Annual pressure test to MAOP
– Continuous pressure monitoring; or
– Smart pigging every 3 years
Above ground– Same as below ground, but
may also use monthly AVO
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INTEGRITY MANAGEMENT: RULE 1104
Must report all Grade 1 Gas Leaks – Initial report within 6 hours of discovery to Director and LGD• Verbal or written• Reported to
– Supplemental report within 10 days of discovery• Topographic map and images of location• Corrective actions, initial mitigation, and investigation measures conducted by operator
– Director may require further reporting
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ACCIDENT REPORTING: RULE 602
Operator must notify the Commission and LGD of safety events or reportable injuries
Initial reporting required within 6 hours of event Accident Report required within 3 days Director may require supplemental reporting
– Information regarding root cause, repairs or other actions
Operator must present to the Commission or review organization its root cause about the accident upon Director’s request
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ABANDONMENT: RULE 1105
Remove from service: lockout or tagout – Precursor to abandonment
Abandonment in Place– Purge line and deplete to atmospheric pressure;– Cut risers to 3 feet below grade and seal ends; and – Remove above ground cathodic protection and equipment
Line Removal – Remove the line, risers above ground cathodic protection and equipment
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ABANDONMENT: RULE 1105
Confirmation of Abandonment
– Reported within 30 days of abandonment on a Form 44
– Director provides Form 44 to UNCC and LGD
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CONTACTS FOR FOLLOW UP
Dave [email protected]
Greg [email protected]
Lucas [email protected]
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2018 Flowline Rule and the
New Flowline Report, Form 44
February 28, 2018
Flowline RulesDEFINITIONS (100 Series)
FLOWLINE REGULATIONS (1100 Series)
1101. Registration Requirements (Form 44)
1102. Flowline and Crude Oil Transfer Line Requirements
1103. Flowline and Crude Oil Transfer Line Valves
1104. Integrity Management
1104.k. Gas Leak Reporting (Form 44)
1105. Abandonment (Form 44)
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Form 44 Registration
• Off Location Flowlines
• Domestic Taps
• Crude Oil Transfer Lines
• Produced Water Transfer Systems
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Registration is required: 1. For new construction after May 1, 20182. For lines existing prior to May 1, 2018,
by October 1, 2019
Form 44 Registration Elements
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a. Materialb. Applicable Technical
Standardsc. Designd. Installatione. Coverf. Top Soil &
Reclamationg. Markingh. Inspection
i. Maintenancej. Repairk. Operating
Requirements l. Corrosion Control m. Record Keeping n. One Call Participation o. Notification of Lines
not in Service
1102. FLOWLINE AND CRUDE OIL TRANSFER LINE REQUIREMENTS
1104 INTEGRITY MANAGEMENT
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1105. ABANDONMENTA line is considered active until fully abandoned.
When a line is not in active use, lockout or tagout.
For abandonment, operators must physically separate the line from all sources of fluids and pressure and may choose
Abandonment in place or
Removal
Form 44 to be submitted 30-days after abandonment with report provided to LGD and UNCC
Form 44
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Form 44 Implementation
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Form 44 Estimated Implementation Schedule
Conceptual Form 44 creation Friday, December 1, 2017 Complete
Preliminary Form 44 creation Monday, January 1, 2018 Complete
Alpha testing Form 44 - Internal testing Monday, January 29, 2018 Complete
Beta testing Form 44 - External testing Monday, February 26, 2018 Scheduled
Form 44 initial training Wednesday, March 21, 2018
Initial release for pre-rule implementation Monday, March 26, 2018
Form 44 subsequent training Wednesday, April 11, 2018
Final release for rule implementation Tuesday, May 1, 2018
Form 44 – Wizard Crude Oil Transfer Line
New Form
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Form 44 – Contact & Operator Information
Form 44 – Crude Oil Transfer Line Tab
Registration
Facility ID, Name and Jurisdiction
As-Built Details• Fluid type• Bedding material• Pipe material• Pipe diameter• Burial depth• MAOP• Test Pressure and date
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Form 44 – Crude Oil Transfer Line Tab
List of Items to Attach• Pressure charts• Layout Drawing• Geodatabase File• Affidavit of Completion
Narrative Description • Corrosion Protection• Integrity Management
Program• Construction Method in
“USA”
Form 44 – AttachmentTab
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Form 44 –Attachment: Layout Drawing
Form 44 Registration
• Off Location Flowlines
• Domestic Taps
• Crude Oil Transfer Lines
• Produced Water Transfer Systems
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Registration is required: 1. For new construction after May 1, 20182. For lines existing prior to May 1, 2018,
by October 1, 2019
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Questions?