The impact of the ESG (Environmental, Social, Governance) movement on government regulations of the US pipeline industry is one of the most significant seen in its 88-year history. The use of fresh water and seawater to hydrotest and abandon onshore and offshore pipelines is of particular concern. Utilizing water to test, monitor, flush and abandon pipelines has and will continue to be the most versatile and economic tool available. However, PHMSA's (Pipeline and Hazardous Materials Safety Administration) new Mega Rule governing onshore pipelines and changes in guidance from BSEE (Bureau of Safety and Environmental Enforcement) for abandonment of offshore pipelines have necessitated both the development of new as well as the improvement of existing technologies. This study examines some of the challenges and potential solutions to meet these new regulatory requirements.
The growth of the development of natural gas resources as the preferred source of energy transition has been very successful in the US. Development of the Barnett, Marcellus, Eagle Ford, Permian, and the Haynesville unconventional shales has resulted in significant increases in the number, size and capacity of gas gathering pipelines. The safety and environmental risks from a release from one of these large diameter pipelines is potentially catastrophic. In response, the PHMSA's Mega Rule added 425,000 miles of natural gas, LNG (liquified natural gas), and product gathering pipelines under similar regulations as those governing transmission lines. Unlike gas transmission pipelines that are designed and constructed to be frequently inspected, gas gathering lines were not.
The offshore pipeline regulatory environment has been evolving for decades. As the governing authority for offshore pipelines, BSEE does not conduct or require any subsea inspections of active pipelines. Pipeline leaks in 2016 and 2017 in the offshore GOM (Gulf of Mexico) caused congress to authorize the GAO (Government Accountability Office) to investigate the robustness of BSEE's enforcement capabilities. BSEE has responded by reviewing the permitting process for decommissioning and requiring changes to existing practices. New requirements for hydrotesting, flushing, and abandonment are needed. The most severe change to practices being considered by regulators is to suspend abandoning pipelines in place. Specifically, requiring pipeline in less than 200 feet of water to be dismantled and removed. This will bring significantly increased costs associated with decommissioning to current operators. This paper shows how existing practices and new advancements offer a better alternative than prohibiting pipeline abandonment in place.
