Pipelines and Facilities Operations Manual

PIPELINE AND FACILITIES OPERATIONS MANUAL

OVERVIEW

Note to Clients:

The Oil and Gas Commission (OGC) has modified the system introduced last year for managing pipelines. This system and related regulatory practices, application forms and processes are described in a new manual. Operators are directed to refer to this new manual for all aspects of pipeline activity.

The table at the end of this document summarizes the changes that have been made to the pipeline regulatory process. The following information provides a more detailed explanation of the same changes and some of the rationale for these changes.

Introduction

The Oil and Gas Commission continues to phase in a "performance-based" approach to managing oil and gas industry performance in British Columbia. OGC effort will shift from reviewing preliminary surface and technical information at the front end of the planning process to assessing the performance of companies' activities against clear, relevant standards.

Starting with the 2004/2005 season, the OGC implemented a number of significant changes that are designed to improve the efficiency and effectiveness of pipeline planning and construction in the industry, as well as application review and pipeline activity compliance monitoring:

The PL 101 form is no longer part of the OGC review process. Engineering companies will therefore no longer receive separate letters from the OGC indicating Certificate and Project Numbers. Engineered technical drawings and detailed specifications are not required at the surface application stage. This information will be submitted at the notice to construct stage after the surface authorizations have been issued and companies are undertaking construction;
Requirements for surface activities and technical specifications will be reflected in regulatory standards until best management practices can be developed. The best management practices will include forestry, aquatic and terrestrial ecosystems, stakeholder and public consultation, and archaeology, and
Pipeline surface access applications will be treated as routine or non-routine. Applications will be treated as routine where either:
1. the pipeline is included in a General Development Plan (GDP) which either has approval in principle or is being processed by the OGC, and the length and location of the pipeline are the same as what was proposed in the GDP; or
2. the application meets the following requirements:
  1. the company commits to following all regulatory standards and best management practices;
  2. Conflicts with landowners, tenure holders and stakeholders have been resolved; and
  3. The pipeline is located outside of CSA class 2, 3 or 4 locations;
  4. The pipeline is located outside the Muskwa-Kechika Management area, Major River Corridors, and Special and Protected Management Land Use Areas as defined in the LRMPs;
  5. The pipeline project is within northeastern BC.

For routine applications, the OGC's role will be limited to the following:

Completion of First Nations consultations (where the OGC has determined that consultation is required).
Completion of status checks for private and Crown land. This will identify potential surface ownership and tenure conflicts. Note: companies will likely be able to complete this step starting in late 2005 with the implementation of the Integrated Land and Resource Registry (ILRR); and
Issuance of surface authorizations including:
1. Land Act - temporary permit to occupy Crown land;
2. Forest Act - cutting permit; and
3. Water Act (if applicable) - permission for changes in or about a stream.

Temporary rights to occupy have been lengthened from 6 months to 24 months. The OGC will continue to issue the documentation for the three-year License of Occupation which is now issued at the final segment of notification of Leave to Open or at the conclusion of the 2 year right of occupancy, or at the conclusion of the 2 year right of occupancy, whichever comes first.
Pipeline surface access authorizations under the Water Act, Land Act and Forest Act will be issued regardless of the status of wells (provided the well has been approved). Companies are no longer required to provide a Notice of Proven Well to the OGC. This component is now within the notice of Leave to Construct.
Companies are able to make minor routing changes or carry out work within a 150 metre corridor containing the proposed right of way for those lines crossing new land and where no other linear disturbance exists. Changes in the routing and right of way within the corridor will be filed with the OGC upon filing the as-cleared surface construction plans which must be submitted with the notification of Leave to Open. The formal Statutory Right of Way is issued when the final legal survey (Statutory Right of Way Plan) is submitted (within two years of Certificate of Operations being issued).
As well, companies can identify temporary work spaces within the 150 metre corridor.. These temporary work spaces must be identified in the application on the construction plan, or if utilizing a corridor, only the total area required for the workspaces must be shown on the construction plan. Companies pay stumpage and consideration on this additional area cleared for temporary work space.
Companies are able to obtain approval of up to five segments of a pipeline project. Initially, this will be achieved by grouping less complex segments that meet "routine" criteria under one application. More complex and sensitive segments should be submitted under a separate non-routine application. The maximum number of segments allowed per application will be reviewed and may be revised for the 2006/2007 season.

Start Original Process	Phase 1 Previous Season	Phase 2 Current Changes
PL101/103 submitted, along with a cover letter on first submission PL101/103 requires detailed pipe/facility specs LTO is requested after pressure tests are preformed by way of a letter PL102/PL104 submitted after construction PL102/PL104 also requires detailed pipe specs (often different from PL101 specs) Certificate of Operations granted. Notification of cancellation, abandonment (prior to 1997), etc. done via a letter of notification Modifications, repairs, relocations, etc. done through the PL101 / PL102 system	Total overhaul of the pipeline application process Removal of the PL101 / PL102 system Change to a new set of forms, which separates and identifies different pipeline activities Surface Rights Form identifies routine vs. non-routine based on geographic areas, special management areas, and following BMPS as well as within existing ROW or GDP Notice of Intent Form - notifies OGC of activities taking place on existing projects Notice of Construction Start Form - self explanatory Notice of Pressure Test Form - self explanatory Leave to Open - at this stage all pipeline specifications are required As-built Form - drawings required at this point, final notice of construction finish	Purpose of these changes is to further "lean out" the requirements and clarify the process, while maintaining legislative requirements Process for amendments and revisions on the Surface Rights Application Form have been included P.Eng sign off required only on the Leave to Open and As-Built forms Regulatory Standards (Legal BMPs) have been outlined PL103/104 removed and incorporated into the new system Minor requirement changes on some of the forms Forms have been further simplified with clearer directives Most technical specifications are now required at the As-Built stage rather than the Leave to Open Major River Corridors and Special and Protected Management Land Use categories as defined in the LRMPs are now non-routine triggers