This article will discuss the nuances associated with submitting Louisiana Tier II reports for pipelines versus conventional facilities. Due to the nature of pipelines, which traverse many different jurisdictions, it is not straightforward to determine how to properly fill out your Tier II report, how many versions of the report you need to complete, and who you need to submit it to.
Information here is based on guidance documents provided by the Louisiana State Police as well as from conversations with the Louisiana State Emergency Response Commission.
Nuance 1: Facility Type
When completing your Tier II report in Encamp, there will be a Louisiana-specific question in the "State Information" section that asks for "Facility Type", with the options "Fixed", "Pipeline", and "Oilfield".
Fixed should be selected for pumping stations or compressor stations that are generally associated with a pipeline.
Pipeline should be selected for the piping elements.
Nuance 2: How many reports do I need?
There are a few guidelines to follow when determining the number of reports you will be filing for a given number of pipelines:
- A report must be completed for every parish that the pipeline traverses.
- If there is more than one pipeline in a parish for a given owner/operator, then all of the pipelines should be reported on one Tier II report for that parish.
- Fixed site facilities (such as pumping stations) must be reported separately.
Example: An owner/operator operates two pipelines (one Crude Oil, one Natural Gas) that traverse East Baton Rouge Parish and West Baton Rouge Parish. There is also one pumping station located in East Baton Rouge Parish.
Result: The owner/operator must file 3 reports. One 'pipeline' report for East Baton Rouge Parish (with two reportable chemicals), one 'pipeline' report for West Baton Rouge Parish (with two reportable chemicals), and one 'fixed' report for the pumping station. (Note: 'Pipeline' and 'Fixed' refer to the facility type discussed in Nuance 1).
Note that LEPCs in Louisiana are organized at the parish level, so be sure to indicate the proper LEPC/parish for each separate 'pipeline' or 'fixed' report you are preparing for the guidelines above.
Nuance 3: Special Reporting Guidelines
For pipeline reports, the Louisiana SERC requests that chemical and pipeline information be reported in a specific way:
- For the facility name field, enter the owner/operator name followed by the facility name (e.g., "Texaco Exploration and Production - Lake Barre Field")
- Following the guidelines in Nuance 2 (for pipelines that are in multiple parishes), each pipeline product should be reported as a separate chemical on the report
- In the 'Storage Location' field, report the diameter of the pipeline and the maximum operating pressure
- In the 'Notes' section, report whether you have previously submitted a map, are on the
current set of DeWitt maps, or are submitting a map for the first time
- For the 'Mailing Address', make sure to put a location where mailed correspondence can be received, as opposed to a physical address that may be associated with the pipeline and is therefore unmanned.
- For the 'Physical Address', it is acceptable to put 'MULTIPLE' or 'PIPELINE' for the street.
Nuance 4: Who to submit reports to
If the guidelines in Nuance 2 have been followed, the proper number of reports have been prepared, taking into consideration the number of parishes that the pipeline traverses.
SERC: All prepared reports would go to the SERC.
LEPC: Because LEPCs in Louisiana are organized at the parish level, you would just need to submit each report to the parish/LEPC indicated on the report.
Fire Department: Each report that you have prepared within each parish would need to be submitted to every Fire Department whose jurisdiction the pipeline passes through.
Using the example presented in Nuance 2, the single 'pipeline' report prepared for East Baton Rouge parish (containing two chemicals, Crude Oil and Natural Gas) would be submitted to the SERC, the East Baton Rouge EPC, and may need to be submitted to multiple Fire Departments within East Baton Rouge parish (such as Baton Rouge Fire Department, Central Fire Protection District, and Saint George Fire Protection District).