Introduction

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin (ADB)-2016-0075 on August 16, 2016, 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. According to the ADB-2016-0075, an out-of-service pipeline remains a regulated pipeline under the PHSMA and the OSFM's jurisdiction.

The ADB-2016-0075 also acknowledged that a purged pipeline presents different risks and different regulatory treatments may be appropriate. Because of the ADB-2016-0075, the OSFM acknowledged certain impractical activities on the purged pipelines. But if an operator intends to operate the subject pipeline, all deferred activities must be up to date, completed, and inspected/verified by the OSFM before the start of the operation.

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:

  1. Cease normal operations for 180 days or more
  2. Be isolated, and
  3. 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.

Procedures

Step 1: Return-to-Service Request

The operator shall submit a return-to-service request at least 60-day in advance to the OSFM, Pipeline Safety Division, Assistant Deputy Director via the Pipeline Notification email: (pipelinenotification@fire.ca.gov).

Each return-to-service request must provide the following information about the pipeline:

  • OSFM Pipeline Identification Number.
  • List of deferred activities (if any)
  • List of special permit's requirements (if any)
  • Commodity contained after the pipeline or segment(s) of the pipeline is/are reactivated.
  • Length of the pipeline segment and the map showing the beginning and the end location of the purged pipeline.
  • Procedure to reactivate the pipeline.
  • Expected dates of field works.
  • Supporting documents to show that all deferred activities are completed.
  • Date of hydrostatic pressure test and/or in-line inspection

Step 2: Field Inspection(s) and/or Records Review

Upon receipt of the return-to-service request, the OSFM may schedule a meeting to review the supporting documents with the operator and may conduct field inspection(s) to verify that the pipeline is reactivated in accordance with the procedure provided by the operator.

Step 3: Acknowledgement

In the end, the OSFM will acknowledge each return-to-service request in a letter.

Program Contact

The OSFM is available to discuss the Return-to-Service Program with any operator in a virtual meeting.

Virtual Meeting Contact:

Andy Chau
Supervising Pipeline Safety Engineer
andy.chau@fire.ca.gov
(562) 305-0679