Out-of-Service Deferral Program
The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin (ADB)-2016-0075 to all operators of Hazardous Liquid and Carbon Dioxide pipelines to clarify the regulatory requirements that may vary depending on the operational status of a pipeline. The ADB-2016-05 suggests that the operators who would like to defer certain activities for purged pipelines should coordinate the deferral in advance with regulatory Agencies, such as CAL FIRE – Office of the State Fire Marshal (OSFM) for intrastate pipelines. According to the ADB-2016-05, a purged pipeline presents different risks and different regulatory treatments may be appropriate. The OSFM will consider each deferral request and accept the deferral activities that are impractical on the purged pipelines.
On December 27, 2020, the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES Act) of 2020 was signed into law. The PIPES Act of 2020 directs the PHMSA to alter its policy to define the idle pipeline and establish requirements for idling and restarting pipelines.
According to this Act, an idle line needs to meet three requirements, including:
- Cease normal operations for 180 days or more
- Be isolated, and
- Either be purged of combustibles and hazardous materials and maintains a blanket of inert, nonflammable gas at low pressure; or contain only limited amounts to be allowed by PHMSA regulations that are to be drafted.
The PIPES Act of 2020 mandates PHMSA to develop the requirements for idled pipelines, and PHMSA will decide in its rulemaking. At a minimum, the statute requires any resumption of operations to be preceded by either a hydrostatic test or in-line inspection.
While PHMSA is developing the requirements for the idle pipelines, the OSFM follows the ADB-2016-0075 to review the deferred maintenance request of purged pipelines from any operator.
Step 1: Deferral Request
The operator shall submit a deferral request to the OSFM, Pipeline Safety Division, Assistant Deputy Director via the Pipeline Notification email: (firstname.lastname@example.org).
Each deferral request must provide the following information about the pipeline:
- OSFM Pipeline Identification Number.
- Commodity contained at the time of application.
- Length of the purged pipeline segment and the map showing the beginning and the end location of the purged pipeline.
- Procedure to purge the hazardous liquid from the pipeline.
- Activities, including the specific regulatory section(s) that the operator is requesting a deferral for.
- Documents to show how the line is isolated from the active pipeline system (e.g. pictures including the GPS location for both ends of the subject pipelines).
- Explanation on why each deferred activity is impractical on the subject pipeline.
Step 2: Field Inspection(s) and/or Records Review
Upon receipt of the deferral request, the OSFM may request the operator to provide the schedule of any field activities on the subject pipeline and may conduct field inspection(s) to verify that the pipeline is purged and cleaned in accordance with the procedure provided by the operator.
At the end of the field activities, the operator shall submit the following supporting documents to the OSFM.
- Records showing that the subject line was purged.
- Pictures and GPS locations of each isolation points.
Step 3: Acknowledgement
Each application of deferral request is assessed in accordance with the criteria outlined in PHMSA-2016-0075:
- The hazardous liquid must be properly purged from the pipeline.
In the end, the OSFM will acknowledge each deferral request in a letter.
The OSFM is available to discuss the Out-of-Service Deferral Program with any operator in a virtual meeting.
Virtual Meeting Contact:
Supervising Pipeline Safety Engineer