On August 16, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin (ADB)-2016-0075 to clarify the regulatory requirements on the operational status of a pipeline under 49 C.F.R. Part 195. This clarification comes after a release of crude oil from an out-of-service pipeline. In this incident, the operator of the pipeline purchased the pipeline with the understanding that the pipeline had been properly purged and cleaned such that no hazardous material is contained in the pipeline.
This incident revealed that the operational status of a pipeline being referred to as idled, inactive, or out-of-service may still contain hazardous materials. While the industry still uses various terms (idled, retired, out-of-service, etc.) on the operational status of a pipeline, those pipelines that have not been abandoned in accordance with the regulation below must comply with the 49 C.F.R. Part 195, subject to the requirements described in the California Government Code, Sections 51010 through 51019.1 and the Office of the State Fire Marshal (OSFM) mileage fee under Title 19, California Code of Regulations.
The process and requirements for pipeline abandonment are captured in 49 C.F.R. Part 195.402 (c)(10) for hazardous liquid pipelines as shown below:
“Abandoning pipeline facilities, include safe disconnection from an operating pipeline system, purging of combustibles, and sealing abandoned facilities left in place to minimize safety and environmental hazards. For each abandoned offshore pipeline facility or each abandoned onshore pipeline facility that crosses over, under, or through commercially navigable waterways the last operator of that facility must file a report upon abandonment of that facility in accordance with 49 C.F.R. Part 195.59 of this part.”
Step 1: Abandonment Request
The operator shall submit an abandonment request to the OSFM, Pipeline Safety Division, Assistant Deputy Director via the Pipeline Notification email: (firstname.lastname@example.org).
The abandonment request must state the intent to abandon a pipeline or segment(s) of a pipeline and must provide the following information about the pipeline:
- OSFM Pipeline Identification Number
- Commodity contained at the time of application for abandonment
- Commodity contained after the pipeline or segment(s) of the pipeline is/are abandoned
- Length of the entire pipeline
- Length of the abandoning pipeline
- Procedure to purge the hazardous liquid from the pipeline
- Expected date to purge/clean the pipeline (if available)
Step 2: Field Inspection(s) and/or Records Review
Upon receipt of the abandonment 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.
- Pictures showing that each isolation points are sealed.
Step 3: Approval
Each application of abandonment is assessed in accordance with the criteria outlined in 49 C.F.R. Part 195.402(c)(10):
- Abandoned pipeline facilities must be disconnected from an operating pipeline system.
- The hazardous liquid must be properly purged from the pipeline.
- All ends must be properly sealed.
Upon approval of abandonment, the OSFM will confirm the abandonment status of the subject pipeline in a letter.
For each abandoned offshore pipeline facility or each abandoned onshore pipeline facility that crosses over, under or through a commercially navigable waterway, the last operator of that facility must file a report upon abandonment of that facility. (See Part 195.59 for details)
The OSFM is available to discuss the Pipeline Abandonment program with any operator in a virtual meeting.
Virtual Meeting Contact:
Supervising Pipeline Safety Engineer