Carbon Dioxide Pipeline
The Office of the State Fire Marshal (OSFM), Pipeline Safety Division, regulates the design, construction, testing, operation, maintenance, emergency planning, and integrity management of intrastate carbon dioxide (CO₂) pipelines in California under the California Pipeline Safety Act, Government Code sections 51010.5 through 51019.1, and Title 19, California Code of Regulations, Division 1, Chapter 14, Article 9, sections 2170 through 2182.
Pursuant to Public Resources Code section 71465(a)(2) a moratorium was placed on pipelines used to transport carbon dioxide to or from a carbon dioxide capture, removal, or sequestration project until after the OSFM adopted regulations governing the safe transportation of carbon dioxide in pipelines. The OSFM has since adopted the required regulations.
For purposes of Article 9, carbon dioxide means a fluid consisting of more than 50 percent carbon dioxide molecules in any combination of gas or dense phases. However, to operate a carbon dioxide pipeline under Article 9, the transported product must consist of more than 90 percent carbon dioxide molecules compressed to a dense phase. (Title 19 CCR §§2170(a)(1) and 2178(b)(2)).
The Office of Administrative Law approved OSFM’s emergency regulations for carbon dioxide pipelines on June 30, 2026. The regulations, under Title 19 of the California Code of Regulations (Article 9, Section 2170 through Section 2182), became effective July 1, 2026. Reference to those regulations for purposes of this webpage are cited as “Article 9”.
Existing Pipelines May Not Be Converted
Existing pipelines originally constructed to transport another liquid or gas may not be converted or retrofitted to transport carbon dioxide. Carbon dioxide pipelines subject to Article 9 must be constructed using new steel pipe, new components, and materials that comply with applicable federal and state pipeline safety requirements.
Relevant authorities include Government Code section 51011.5(d) and (e), and Title 19 CCR section 2174(a).
OSFM is not a California Environmental Quality Act (CEQA) lead agency for a project that includes construction of a carbon dioxide pipeline, see Government Code section 51011.6(b).
If one or more sensitive receptors are located within the Emergency Planning Zone, as defined in Government Code section 51010.5(b), the operator may not construct the pipeline unless a validated, engineering-based computational fluid dynamics or vapor dispersion analysis demonstrates that the risk of exposure to carbon dioxide from a pipeline rupture is within an acceptable range as determined by the CEQA lead agency.
For carbon dioxide pipelines, the Emergency Planning Zone is the area within two miles on either side of the pipeline, measured from the pipeline centerline. Sensitive receptors include locations such as residences, schools, daycare centers, healthcare facilities, long-term care facilities, community resource centers, parks, playgrounds, and businesses open to the public.
Relevant authorities include Government Code section 51011.6(a) and (b)
Step 1 – Notify OSFM Before Construction
At least 60 days before beginning new construction, replacement, or relocation of a carbon dioxide pipeline, the operator must notify OSFM by submitting Form PSD-104, “Notification of Proposed Carbon Dioxide Pipeline Construction.”
All notifications and required submissions to OSFM under Article 9 must be submitted electronically to PipelineNotification@fire.ca.gov.
Relevant authority: Title 19 CCR sections 2180 and 2180.1.
Step 2 – Submit Emergency Planning Zone Information and Implement an Engagement Program
The operator must submit the Emergency Planning Zone inventory and map to OSFM and the applicable CEQA lead agency.
The submittal must include:
●A list of all sensitive receptors within the Emergency Planning Zone.
●A detailed map showing the location and distance of each sensitive receptor from the pipeline.
●A graphic representation of the vapor dispersion analysis, when required.
The operator must update the Emergency Planning Zone inventory and map at least once every three years, or submit a no-change notification if no changes have occurred. The operator must also review the sensitive receptor list annually and provide sensitive receptors with a redacted Emergency Planning Zone map as required by Government Code section 51015.06.
The operator must develop and implement an engagement program with external stakeholders for each pipeline under construction and throughout the life of those pipelines in accordance with API RP 1185 and 19 CCR section 2173(c).
Relevant authority: Title 19 CCR section 2177.1 and Government Code section 51015.06.
Step 3 – Construction and OSFM Inspection
During construction, the operator must construct the pipeline in accordance with Article 9 and applicable federal pipeline safety requirements.
The operator must:
●Notify OSFM of construction activities requiring inspection.
●Provide OSFM inspectors safe access to the construction site.
●Make construction records available to OSFM upon request.
●Correct deficiencies identified by OSFM before the pipeline is placed into service.
Construction requirements include, but are not limited to, design requirements, fracture control, material compatibility, valve placement, leak detection, vapor detection, geohazard protection, cover requirements, coating protection, quality assurance, and nondestructive examination of girth welds.
Step 4 – Notify OSFM Before Pressure Testing or In-Line Inspection
The operator must notify OSFM at least three working days before conducting pressure testing or in-line inspection.
This includes:
●Hydrostatic pressure testing,
●Spike hydrostatic pressure testing, when required, and/or
●In-line inspection.
OSFM inspectors may witness these activities.
Relevant authority: Title 19 CCR sections 2176, 2176.2, 2176.3, and 2180.
Step 5 – Before Operation and Ongoing Compliance
Before placing a carbon dioxide pipeline into operation, the operator must have a written Carbon Dioxide Pipeline Safety Program with procedures and emergency planning measures that comply with Article 9.
Ongoing requirements include, but are not limited to:
●Operations and maintenance procedures.
●Integrity management.
●Leak detection and vapor detection systems.
●Emergency response planning.
●Emergency responder training.
●Emergency preparedness materials for sensitive receptors.
●Annual and periodic review of required procedures, analyses, maps, and records.
●Retention of records demonstrating compliance for the life of the pipeline and components.
OSFM may inspect pipeline facilities, review records, require corrective action, and take enforcement action when necessary to protect public safety.
If you have any questions about the carbon dioxide program, please contact the OSFM at PipelineNotificaiton@fire.ca.gov