Pipeline Abandonment and Regulatory Compliance
In response to a crude oil release from an out-of-service pipeline, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin (ADB)-2016-0075 on August 16, 2016. This bulletin aimed to clarify the regulatory requirements concerning the operational status of pipelines under 49 C.F.R. Part 195. The accident that prompted this clarification involved an operator who had purchased a pipeline under the assumption that it had been properly purged and cleaned, thereby containing no hazardous materials.
This accident shed light on the fact that pipelines referred to as idled, inactive, or out-of-service may still pose risks due to the presence of hazardous materials. While different terms are still used within the industry to describe the operational status of a pipeline (such as idled, retired, out-of-service, etc.), pipelines that have not been officially abandoned in accordance with 49 C.F.R. Part 195.402(c)(10) must comply with 49 C.F.R. Part 195, California Government Code, Sections 51010 through 51019.1, as well as the Office of the State Fire Marshal (OSFM) mileage fee under Title 19, California Code of Regulations.
In the case of a purged pipeline, operators may have the option to request a deferral of maintenance activities. The specifics of this deferred maintenance program can be found on the deferred maintenances website. It is advisable for operators to refer to the program's guidelines and requirements for detailed information on how to proceed with deferred maintenance activities for purged pipelines.
The process and requirements for pipeline abandonment are specified in 49 C.F.R. Part 195.402 (c)(10) for hazardous liquid pipelines. According to this regulation, abandoning pipeline facilities involves several steps to ensure safety and minimize environmental hazards. These steps include the safe disconnection of the facility from the operating pipeline system, the purging of combustible materials, and the proper sealing of abandoned facilities that are left in place. Additionally, for each abandoned offshore pipeline facility or onshore pipeline facility that crosses over, under, or through commercially navigable waterways, the last operator of that facility is required to file a report upon abandonment in accordance with 49 C.F.R. Part 195.59 of the same regulation.
Step 1: Abandonment Request
To initiate the abandonment process, the operator is required to submit an abandonment request to the Assistant Deputy Director of the Pipeline Safety Division at the OSFM (Office of the State Fire Marshal). The request should be sent via email to the Pipeline Notification address: firstname.lastname@example.org.
The abandonment request must clearly state the operator's intention to abandon either the entire pipeline or specific segment(s) of the pipeline. Additionally, the following information about the pipeline should be provided:
- OSFM Pipeline Identification Number
- Commodity contained in the pipeline at the time of the abandonment request
- Commodity that will remain in the pipeline after abandonment
- Total length of the entire pipeline
- Length of the specific segment(s) being abandoned
- Procedure for purging the hazardous liquid from the pipeline
- Expected date for purging/cleaning the pipeline (if available)
Step 2: Field Inspection(s) and/or Records Review
Upon receiving the abandonment request, the OSFM may request the operator to provide a schedule of any field activities related to the pipeline. The OSFM may also conduct field inspection(s) to verify that the pipeline has been purged and cleaned in accordance with the procedure provided by the operator.
At the completion of the field activities, the operator must submit the following supporting documents to the OSFM:
- Records demonstrating that the subject pipeline has been successfully purged
- Pictures and GPS locations of each isolation point
- Pictures showing that each isolation point has been properly sealed
Step 3: Approval
Each abandonment application is carefully assessed based on the criteria specified in 49 C.F.R. Part 195.402(c)(10). The following conditions must be met:
- Abandoned pipeline facilities must be disconnected from the operating pipeline system.
- The hazardous liquid must be thoroughly purged from the pipeline.
- All ends of the pipeline must be securely sealed.
Upon approval of the abandonment, the OSFM will issue a letter confirming the abandonment status of the subject pipeline.