Pathways for Restarting Pipelines
Requirements for Restarting the CA-324 and CA-325 Revised: May 23, 2024
When they were in operation, lines CA-324 and CA-325 (previously known as Lines 901 and 903), transported crude oil from the Santa Ynez Unit, which comprises an onshore oil and natural gas processing facility, three offshore platforms, and associated offshore pipelines.
These operations are subject to significant regulatory oversight, with the CAL FIRE - Office of the State Fire Marshal (OSFM) acting as the safety and enforcement regulatory authority over these pipelines. Platforms and offshore pipelines associated with CA-324 and CA-325 also fall under the jurisdiction of various other regulators, including the Pipeline and Hazardous Materials Safety Administration (PHMSA), State Lands Commission, and Bureau of Safety and Environmental Enforcement, among others. Those regulators maintain their own requirements for restart of platforms and pipelines that may not fall directly under the OSFM jurisdiction.
Before restarting CA-324 and CA-325, pipeline operators must adhere to specific standards regulated by the OSFM, including strict compliance with all the listed requirements below.
The Coastal Best Available Technology (CBAT) was enacted by the OSFM pursuant to legislative mandates imposed in response to the Refugio Beach pipeline spill in May 2015. It mandates the use of the best available technology for pipelines in environmentally sensitive coastal areas to minimize oil spills.
In adhering to CBAT regulations, operators are required to submit a risk analysis to the OSFM for approval. If an operator identifies the best available technology to mitigate the quantity of hazardous liquid spills in case of a release, it must specify these technologies and propose their retrofitting into the pipeline. Following the installation of these technologies, the OSFM will review the operator's records to confirm compliance with CBAT regulations.
In 2021, the OSFM approved a risk analysis and implementation plan for the lines, which included the installation of valves and incorporating other technologies into the pipelines. To proceed with implementing this technology, the operator needs permits for installing or upgrading specific safety valves in Santa Barbara County. The OSFM does not handle local permit issuance, and recommends stakeholders contact relevant agencies for updates on those processes as outlined in the approved plan.
In November 2023, the pipeline owner presented an alternative risk analysis to the OSFM for review and approval. The November 2023 risk analysis was withdrawn in March 2024.
On April 11, 2024, Pacific Pipeline Company submitted an alternative risk analysis and implementation plans to amend the current plan. The OSFM is currently reviewing the April 2024 alternative risk analysis.
References:
- Coastal Best Available Technology, Office of State Fire Marshal, Retrieved from: https://osfm.fire.ca.gov/what-we-do/pipeline-safety-and-cupa/coastal-best-available-technology
- 901/903 Valve Upgrade, County of Santa Barbara Planning and Development, Retrieved from: https://www.countyofsb.org/880/901903-Valve-Upgrade
- Plains’ Risk Analysis and Implementation Plan, Coming Soon.
After the Refugio spill, CA-324 and CA-325 were subject to the obligations of a Consent Decree mandated by the United States District Court, Central District of California (Civil Action No. 2:20-cv-02415). This decree stipulates a series of prerequisites that must be met before any restart of these lines can be initiated. The operator is responsible for submitting reports and involving the OSFM in reviewing the subject pipelines' compliance with the requirements outlined in the Consent Decree. The California-specific provisions are found in Appendix B of the Consent Decree, and include:
- State Waiver
- Replacement, Restart, or Abandonment of the pipelines
- Integrity Management
- Valves
- Risk Analysis
- Leak Detection
The Appendix should be read in conjunction with the entire Consent Decree for a full understanding of the relevant requirements.
Reference:
- Consent Decree Civil Action No. 2:20-cv-02415, United States District Court, Central District of California, Retrieved from: https://www.epa.gov/sites/default/files/2020-03/documents/plainsallamericanpipelinelp.pdf
The Integrity Management Program established by the PHMSA on regulated pipelines is a framework designed to ensure the safe operation of pipelines. This program requires pipeline operators to implement measures to assess and mitigate risks associated with pipeline integrity, with the goal of preventing incidents such as ruptures, or failures.
As part of the integrity management program, the OSFM mandates that active pipelines undergo an Integrity Assessment test at least once every five years. These assessments typically involve either a hydrostatic pressure test or an In-Line inspection using a smart tool. The OSFM reviews and evaluates integrity assessment reports for each regulated pipeline. Since the pipelines in question are currently idle, both must undergo integrity assessment testing and implement relevant preventive and mitigative actions before restarting.
Reference:
- Hazardous Liquid Integrity Management (HL IM), Retrieved from: https://www.phmsa.dot.gov/pipeline/hazardous-liquid-integrity-management/hazardous-liquid-integrity-management-hl-im
A State Waiver is an order that modifies compliance with a regulatory requirement if an operator demonstrates that alternative measures are consistent with pipeline safety. The OSFM evaluates state waiver applications in consultation with the PHMSA to determine if the proposed alternative measures can provide an equal or greater level of safety than the required regulation, and may grant a state waiver accordingly.
Certain provisions of the Consent Decree mandate that the pipeline operator applies for a State Waiver through OSFM regarding the limited effectiveness of cathodic protection on CA-324 and CA-325. The pipeline operator must obtain a State Waiver from the OSFM and a no-objection from PHMSA before restarting the respective pipelines.
References:
- Pipeline Safety: Ineffective Protection, Detection, and Mitigation of Corrosion Resulting From Insulated Coatings on Buried Pipelines, Retrieved from: https://www.federalregister.gov/documents/2016/06/21/2016-14651/pipeline-safety-ineffective-protection-detection-and-mitigation-of-corrosion-resulting-from
- Special Permits and State Waivers Overview, United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration, Retrieved from: https://www.phmsa.dot.gov/pipeline/special-permits-state-waivers/special-permits-and-state-waivers-overview
The OSFM continues to oversee idle pipelines under 49 CFR Part 195 and the Elder Pipeline Act until a pipeline is formally abandoned, at which point it is removed from the OSFM’s program. An idle pipeline remains temporarily inactive and is not involved in transporting hazardous materials. If the pipeline is purged of hydrocarbon substances, the operator may request to postpone specific maintenance tasks as outlined in PHMSA Advisory Bulletin 2016-0075. Both pipelines have deferred certain maintenance activities, and all the deferred maintenance must be completed before operations can resume.
References:
- Out-of-Service Deferral Program, Office of State Fire Marshal, Retrieved from: https://osfm.fire.ca.gov/what-we-do/pipeline-safety-and-cupa/out-of-service-deferral-program
- Pipeline Safety: Clarification of Terms Relating to Pipeline Operational Status, PHMSA Advisory Bulletin 2016-0075, Retrieved from: https://www.phmsa.dot.gov/regulations/federal-register-documents/2016-19494
A pipeline startup plan delineates the procedures and protocols for safely restarting the operation of a pipeline system. Prior to the potential restart of operations, the OSFM will review the startup plan and perform on-site inspections of the pipelines to verify compliance to the plan.
Appendix D of the Consent Decree specifies the minimum requirements for restarting CA-324 and CA-325. The restart plan typically represents the final step in resuming operations. After the pipeline operator fulfills all other necessary requirements, OSFM finalizes the specific requirements of the restart plan, ensuring they meet or exceed those mandated by the Consent Decree.
The OSFM remains steadfast in its commitment to pipeline safety, serving the interests of both the State and local communities. Both CA-324 and CA-325 must fulfill all the aforementioned requirements before restarting operations. The pipeline operator must undergo a multi-stage review process to comply with these requirements and is expected to work with other agencies to meet their regulations, including any environmental review, before potentially restarting the subject pipelines.