In This Issue

Annual Inspections of Intra-State Liquid Pipelines and Operators in California

As a result of the May 19, 2015 pipeline incident at Refugio Beach in Santa Barbara County that spilled over 100,000 gallons of crude oil and impacted over 25 miles of coastline and ocean water, the State of California has mandated the Office of the State Fire Marshal (OSFM) to adopt regulations and conduct annual inspections of each intrastate hazardous liquid pipeline to reduce the potential pipeline accidents in California and protect the environment.

The State Fire Marshal has provided notice to adopt proposed regulations related to the annual pipeline inspection of every intrastate hazardous liquid pipeline and operators of intrastate hazardous liquid pipelines. The OSFM annual inspection will ensure compliance with federal and State regulations, enhance public safety, protect California’s vital natural resources, and reduce the risk of future jurisdictional hazardous liquid pipeline accidents. The OSFM annual inspection is a two phase risk-based inspection approach with 4 main components:

  1. Gather Operator Information: Beginning in 2017, each pipeline operator will be required to annually complete and submit to the OSFM the Form PSD-101 by July 1st. The completed form will contain data and validated inspection results from the previous calendar year for each jurisdictional pipeline and scheduled projects for the next calendar year. Operators must maintain documentation to substantiate the information provided in their Form PSD-101. If an operator is unable to submit the Form PSD-101 by July 1st, they may submit a written request to the OSFM asking for a 30-day extension. This written request must be submitted to the Pipeline Safety Division Lakewood Office no later than June 1st.
  2. Internal OSFM Review/Identify Inspection Modules: OSFM staff will review each submitted Form PSD-101 for completeness. OSFM will also review leak, violation, and inspection history from internal databases to identify risks, trends, and other pipeline safety issues on each pipeline. The OSFM will assign inspection modules for each jurisdictional hazardous liquid pipeline based on pipeline operating history, integrity testing, preventative and mitigative measures, construction activities, and the OSFM internal review.
  3. Annual Operator Inspection: The OSFM will schedule an annual operator inspection after the OSFM has assigned inspection modules to an operator?s jurisdictional hazardous liquid pipelines. This operator inspection will include reviewing records associated with the completed Form PSD-101 and discussing the inspection modules that have been assigned to each of the operator’s pipelines for the coming year. Prior to the inspection, operators will be informed as to which documents must be available during the annual operator inspection. This will allow the operator to compile the required documentation from regional offices and have essential personnel available during the inspection. NOTE: Additional inspection modules may be assigned to a pipeline based on information obtained during the annual operator inspection.
  4. Annual Pipeline Inspection: The OSFM staff will conduct an annual pipeline inspection on each pipeline listed on the operator?s Form PSD-101 using the annual inspection modules that were assigned to each pipeline.

By May 1st of each year, the OSFM will provide each California intrastate pipeline operator an electronic version of each Form PSD-101 to the operator staff that has been designated to complete the annual OSFM Pipeline Questionnaire. The Form PSD-101 will be populated with the company information (Name, ID, Inspection Units, and CSFM Line ID) that is currently on file with the OSFM. The Form PSD-101 will be divided by OSFM Inspection Unit and will include each OSFM jurisdictional pipeline that was included in the OSFM Annual Questionnaire for the previous year. Each pipeline operator is required to annually complete and submit a Form PSD-101 to OSFM by July 1st that represents the operator?s pipeline assets as of December 31st of the previous calendar year. The completed Form PSD-101 will identify scheduled projects for the next calendar year and will contain inspection data and validated inspection results from the previous calendar year for each jurisdictional pipeline. Operators must maintain documentation to substantiate the information provided in their Form PSD-101.

These new regulations can be found in California State Regulations, Title 19 – Public Safety, Division 1 – State Fire Marshal, Division Chapter 14 – Hazardous Liquid Pipeline Safety.

There is a new article 2 (sections 2020-2030) filed 2-9-2017; operative 2-9-2017 pursuant to Government Code section 11343.4(b)(3) (Register 2017, No. 6). Article 2 states:

Article 2. Annual Inspection of Intrastate Hazardous Liquid Pipelines and Operators of Intrastate Hazardous Liquid Pipelines

§ 2020. Annual Inspection.

In order to implement Section 51015.1 (a) of the Government Code, the Office of the State Fire Marshal shall conduct an annual inspection of every intrastate hazardous liquid pipeline and every operator of an intrastate hazardous liquid pipeline. The inspection shall include the following:

  • Evaluation of the risks to each intrastate hazardous liquid pipeline based upon the operator history, integrity testing results, preventative and mitigative measures, construction activities, leak history, and compliance history.
  • An annual inspection of each operator of an intrastate hazardous liquid pipeline in accordance with California State Fire Marshal Annual Inspection Procedures (dated July 1, 2016) which is hereby incorporated by reference.
  • An annual inspection of each intrastate hazardous liquid pipeline in accordance with California State Fire Marshal Annual Inspection Procedures (dated July 1, 2016) which is hereby incorporated by reference.
§ 2021. Form PSD-101 Requirements.
  • The following forms, in the format developed by the Office of the State Fire Marshal, which are hereby incorporated by reference, shall be used for hazardous liquid pipeline annual inspections
    • California Intrastate Pipeline Operator Annual Report, PSD-101 (dated July 1, 2016).
    • Instructions for Form PSD-101 (dated July 1, 2016).
  • Each operator of an intrastate hazardous liquid pipeline shall complete and submit to the Office of the State Fire Marshal Form PSD-101 for each intrastate hazardous liquid pipeline no later than July 1st annually.
  • Each operator of an intrastate hazardous liquid pipeline shall have available for review by the Office of the State Fire Marshal documentation to substantiate the information provided in the Form PSD-101.
§ 2030. Violations.

Failure to comply with any of the above provisions of this chapter shall be subject to enforcement action under Section 51018.6 of the Government Code.