Note: Supersedes NTL 2005-G14
Editor’s note: This NTL applies to pipeline right-of-way holders on the OCS, which includes DOT regulated pipelines (DOT pipelines have to get a right-of-way agreement from the MMS to install pipelines on the OCS, even though they are under the jurisdiction of the DOT for design, operations, and maintenance purposes). However, the regulations specifically cited to justify the inspections required below are only applicable to DOI (i.e. MMS, not DOT) pipelines. The MMS has not yet replied to our request for clarification about this (understandably, as they have lots of things to worry about at the moment). We recommend that DOT pipeline operators on the OCS comply with this NTL, even if it could reasonably be argued that it shouldn’t apply as written.
The Minerals Management Service has issued a Notice to Lessees (NTL) to lessees and pipeline right of way holders requiring inspections of OCS Pipelines potentially impacted by Hurricane Katrina. Pursuant to 30 CFR 250.1005(a), you must conduct inspections of pipeline routes at intervals and using methods prescribed by the MMS. Under this authority, and because of the numerous reports of severe damage to OCS pipelines along the path of Hurricane Katrina, the MMS GOMR hereby directs you to conduct the following inspections for facilities located east of longitude 91ş 30’ (91.5ş) by May 1, 2006 (NOTE – this area is different from the area requiring Structural inspections):
- Pipeline Tie-in and Crossing Inspections — Conduct an underwater visual inspection using divers or ROV, a scanning sonar processor, or a 500-kHz sidescan sonar in combination with a magnetometer to inspect each of your OCS pipeline tie-ins and foreign pipeline crossings in water depths less than 300 feet. Design each inspection to determine whether any valves or fittings became exposed and to determine the extent of any damage, including damage to protective devices, mats, and sandbags. If during the course of inspecting pipeline tie-ins and crossings there are indications of pipeline movement, conduct an underwater pipeline inspection described in Item No. 4 below regardless of water depth.
- Pipeline Riser Inspections — Conduct a visual inspection of the above-water portion of each pipeline riser in all water depth ranges. If applicable, conduct this riser inspection in conjunction with the required platform Level I survey described above. Inspect the riser and riser clamps for damage. If this inspection indicates that damage may have occurred, conduct an underwater riser and pipeline inspection to determine if the pipeline has been displaced or exposed.
- Pipeline Steel Catenary Riser Inspections — Conduct an inspection using divers or ROV of the underwater portions of each of your OCS pipeline steel catenary risers. Inspect the riser, vortex-induced vibration (VIV) suppression devices, and the connection point (flexible element, titanium stress joint, etc.) to the structure for damage.
- Additional inspections — If you suspect that Hurricane Katrina may have damaged a pipeline or related structure that is located west of longitude 91ş 30’ (91.5ş) conduct the appropriate inspections described in Items Nos. 1, 2, and 3, above.
You should submit your inspection results to MMS by Oct 14, 2005, then the first Friday of each month thereafter. Remember that a repair procedure must be submitted prior to conducting any repair operations. If you haven’t already done so, perform a leak test before you return to service any pipeline located east of longitude 91ş 30’ (91.5ş). Make sure that the leak test successfully tests the integrity of the pipeline. When you conduct a leak test, make sure that you use a stabilized pressure that is capable of detecting all leaks; use pressure gauges and recorders that are sufficiently accurate to determine whether the pipeline is leaking during the test; and conduct the test for at least two hours during daylight hours. For major oil pipelines, provide aerial surveillance of the pipeline route while you perform the test.
Address any questions regarding pipeline inspections or reports to Mr. Alex Alvarado of the GOMR Pipeline Section by telephone at (281) 986-6157, (281) 755-5204 or by e-mail at pipelines@mms.gov.