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.