Pipeline Abandonment - A Discussion Paper on Technical and Environmental Issues
Prepared for the Pipeline Abandonment Steering Committee (comprised of representatives from the Canadian Association of Petroleum Producers, the Canadian Energy Pipeline Association, the Alberta Energy and Utilities Board, and the National Energy Board)
November 1996
Visit the Alberta Energy Utilities Board (EUB) Web site to view the companion document entitled "Pipeline Abandonment Legal Working Group Report". You can log in as a guest and search for the words "pipeline abandonment".
Disclaimer
This Discussion Paper was prepared under the auspices of the Pipeline Abandonment Steering Committee, a Committee comprised of representatives and employees of the Canadian Association of Petroleum Producers (CAPP), the Canadian Energy Pipeline Association (CEPA), the Alberta Energy and Utilities Board (EUB), and the National Energy Board (NEB). While it is believed that the information contained herein is reliable, CAPP, CEPA, the EUB, and the NEB do not guarantee its accuracy. This paper does not necessarily reflect the views or opinions of CAPP, CEPA, the EUB, or the NEB, or any of the
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Table of Contents
Committee Representative Lists
1. Introduction
1.1 Background
1.2 Review Initiatives
1.3 Scope
1.4 Abandonment Options
1.5 Objective
1.6 Regulatory Requirements
2. Developing an Abandonment Plan
3. Technical and Environmental Issues
3.1 Issue Identification
3.2 Land Use Management
3.3 Ground Subsidence
3.4 Soil and Groundwater Contamination
3.5 Pipe Cleanliness
3.6 Water Crossings
3.7 Erosion
3.8 Road, Railway, and Utility Crossings
3.9 Creation of Water Conduits
3.10 Associated Apparatus
3.11 Cost of Abandonment
4. Post-Abandonment Responsibilities
Appendices
- Current Regulatory Requirements
- Abandonment Checklist
- Industry Questionnaire
- Cleaning Guidelines
- Bibliography
Executive Summary
The Canadian oil and gas industry and federal and provincial regulatory authorities recognize the need to develop guidelines that companies can follow in order to abandon oil and gas pipelines in an environmentally sound, safe, and economical manner. To meet this objective, the Canadian Association of Petroleum Producers and the Canadian Energy Pipeline Association (through their industry participants) have participated along with the National Energy Board and various departments of the Government of Alberta in the development of this discussion paper.
This paper reviews the technical and environmental issues associated with pipeline abandonment and is intended to provide a basis for further discussion on the issue. In order to complete the assessment of this issue, a review of the legal and financial aspects of pipeline abandonment need to be undertaken. More particularly, the core issues of long-term liability and funding need to be addressed both in the context of orphaned pipelines and those with an identifiable owner/operator.
This paper is intended to assist a company in the development of an abandonment plan through the recognition of the general issues which result from the abandonment of a pipeline and by providing the means to address those issues. Land use management, ground subsidence, soil and groundwater contamination, erosion, and the potential to create water conduits are among the topics addressed.
Some follow-up may be required in respect of the technical analysis presented on the issue of ground subsidence. It is suggested that tolerance criteria be developed and that the industry survey referred to in the paper be complemented with a field investigation program. Scale modelling could also be performed to confirm the theoretical ground subsidence calculations.
As illustrated by the diagram on the following page, the pipeline abandonment planning process is a multi-dimensional exercise that requires wide stakeholder input. The abandonment project schedule should also provide an opportunity for meaningful input into the planning process by the affected public, as defined by the scope of the project. It is especially important that landowners and land managers have a central role in this process.
In practice, the decision to abandon in place or through removal should be made on the basis of a comprehensive site-specific assessment. In this context, the analysis presented in this paper has limitations in that all site specifics could not possibly be addressed, particularly in relation to potential environmental impacts or impacts on land use.
The development and implementation of a pipeline abandonment plan that will both minimize impacts to the environment and land use and be cost-effective requires many activities similar in scope to the planning or installation of a new pipeline. For any large-scale abandonment project, it is unlikely that any one abandonment technique will be employed. Rather, a project will usually involve a combination of pipe removal and abandonment-in-place along the length of the pipeline. A key factor influencing the choice between the two options is present and future land use.
In summary, the key features of a proper abandonment plan are
(i) that it be tailored to the specifics of the project,
(ii) that an early and open opportunity be provided for public and landowner input, and
(iii) that it comply with current regulatory requirements. It is also necessary that the plan be broad in scope and encompass post-abandonment responsibilities in the form of right-of-way monitoring and remediation of problems associated with the abandonment.
A major issue still to be addressed is the question of who would assume responsibility if the owner/operator becomes insolvent. In this regard, industry has established a fund in Alberta to cover the cost of reclamation and abandonment of orphaned oil and gas wells and certain associated pipeline facilities.
Committee Representative Lists
Steering Committee
Bob Hill (Chair) Jim Dilay Ken Sharp Ian Scott (Secretary) John McCarthy Fred Webb |
Canadian Energy Pipeline Association Alberta Energy and Utilities Board Alberta Energy and Utilities Board Canadian Association of Petroleum Producers National Energy Board Pembina Corporation |
Technical Subcommittee
Ron McKay (Chair) Tom Pesta Ian Scott Arnold Bell Marsh Yerichuk Robert Power Christine van Egmond Frank Hagedorn Glen Fyfe Rudy Wartlik |
Novagas Clearinghouse Ltd. Alberta Energy and Utilities Board Canadian Association of Petroleum Producers Federated Pipe Lines Ltd. Interprovincial Pipe Line Inc. National Energy Board National Energy Board NOVA Gas Transmission Ltd. Pembina Corporation Westcoast Energy Inc. |
Environmental Subcommittee
Karen Etherington (Chair) Keith Lyseng Wayne Tedder Ivan Weleschuk Dennis Bratton Adolf Bruneski Paul Vasseur Jim Anderson Fred Kuipers |
NOVA Gas Transmission Ltd. Alberta Agriculture, Food and Rural Development Alberta Agriculture, Food and Rural Development Alberta Energy and Utilities Board Alberta Environmental Protection Alberta Environmental Protection Alberta Agriculture, Food and Rural Development (Farmers Advocate) National Energy Board Pembina Corporation |
Abbreviations
AEP H2S |
Alberta Environmental Protection Conservation and Reclamation Canadian Association of Petroleum Producers Canadian Energy Pipeline Association Environmental Protection and Enhancement Act (Alberta) Alberta Energy and Utilities Board (formerly the Alberta Energy Resources Conservation Board) hydrogen sulphide kilometre millimetre National Energy Board outside diameter polychlorinated biphenyl right-of-way |
Glossary of Terms
Abandonment | Refers to the permanent removal from service of the pipeline. A section of pipeline can be abandoned in place or removed. In theformer case, it is assumed that cathodic protection of the pipeline is discontinued and that no other measures are taken to maintain the structural integrity of the abandoned pipeline (other than the potential use of solid fill material at roadway and railway crossing sites or other locations sensitive to ground subsidence). |
Associated Apparatus |
All apparatus associated with a pipeline system, both above and below the ground surface, including pipeline risers, valve assemblies, signage, pig traps, culverts, tanks, and sumps. |
Cathodic Protection |
A technique to prevent the corrosion of a metal surface by making the surface the cathode of an electrochemical cell. |
Corrosion | The deterioration of metal as a result of an electrochemical reaction with its environment. |
Deactivation | Refers to the temporary removal from service of the pipeline. In the context of this paper, it is assumed that corrosion control measures are maintained. |
Decontamination | The removal or neutralization of chemical substances or hazardous material from a facility or site to prevent, minimize, or mitigate any current or future adverse environmental effects. |
Decommissioning | One of the steps of pipeline abandonment, generally involving the physical removal of all above-ground appurtenances. |
Discontinued | See "deactivation". |
Erosion | The process of wearing away the earth's surface through the action of wind and water. |
Groundwater | All water under the surface of the ground. |
Land Surface Reclamation |
The stabilization, contouring, maintenance, conditioning, or reconstruction of the surface of the land to a state that permanently renders the land with a capability that existed just prior to the commencement of abandonment activities, and as close as circumstances permit to that which existed prior to pipeline installation. |
Negative Salvage |
The net cost of abandoning a pipeline through removal, calculated as the cost of removal less salvage revenue generated from the sale of the removed material for scrap or use by others. |
Orphaned | Pipelines and associated facilities for which the licensee and successors are insolvent or non-existent. |
Owner /Operator |
The individual, partnership, corporation, public agency, or other entity that owns and/or operates the pipeline system. |
Pipe Cleaning |
The removal of all substances (solid, liquid, or gaseous) and build-ups within the pipeline to a pre-determined level. |
Pipeline | All metallic onshore pipelines within the scope of the CSA Z662-94 "Oil and Gas Pipeline Systems" standard, including associated appurtenances such as valve assemblies, drip pots, cathodic protection beds, signage, and headers, but not including station facilities such as pump or compressor stations. |
Pipeline System |
The combination of pipelines, stations, and other facilities required for the measurement, processing, storage, and transportation of oil, gas, or other hydrocarbon fluid. |
Reclamation | Any one of the following:
|
Removal | The pipeline is completely removed from the right-of-way. |
Roach | Excess soil placed over the ditch line to compensate for soil settlement. |
Road or Railway Crossing |
The crossing by a pipeline of a highway, road, street, or railway. |
Sight Block |
A mechanism to restrict the visual impact of a pipeline right-of-way. |
Soil | The naturally occurring, unconsolidated mineral or organic material at least 10 centimetres thick that occurs at the earth's surface and is capable of supporting plants. It includes disturbance of the surface by human activities such as cultivation and logging but not displaced materials such as mine spoils. |
Spoil | Soil materials other than topsoil excavated from the trench. In most cases, the excavated soil is suitable for return to the pipeline trench, and allows for re-contouring of the right-of-way. |
Subsoil | Although a common term it cannot be defined accurately. It may be the B horizon of a soil with a distinct profile. It can also be defined as the zone below the plowed soil in which roots normally grow. |
Surface Water |
Water in a watercourse and water at a depth of not more than 15 metres beneath the surface of the ground. |
Suspension | The cessation of normal operation of a pipeline pursuant to its licensed use. The pipeline need not be rendered permanently incapable of its licensed use, but must be left in a safe and stable state during this period of suspension, as prescribed by the applicable regulations and guidelines. See also "deactivation". |
Topsoil | The organo-mineral surface "A", organic surface "O" horizon, or dark coloured surface soil materials, used synonymously with first lift. First lift materials are usually removed to the depth of the first easily identified colour change, or to specified depth where colour change is poor, and contain the soil Ah, Ap, O, or Ahe horizon. Other horizons may be included in the first lift if necessary. |
Water | All water on or under the surface of the ground. |
Water Conduit |
A channel for conveying water. In the context of pipeline abandonment, refers to a pipeline that has become corroded and perforated and transports ground or surface water to a different location. |
Watercourse | (i) The bed and shore of a river, stream, lake, creek, lagoon, swamp, marsh, or
other natural body of water; or (ii) a canal, ditch, reservoir, or other man-made surface feature, whether it contains or conveys water continuously or intermittently. |
Section 1 - Introduction
1.1 Background
Approximately 540,000 km of operating oil and gas pipelines currently exist in Canada, about 50 percent of which are located in Alberta. Ultimately, all oil and gas pipelines will reach the end of their useful lives, and will be abandoned. The issue of pipeline abandonment should therefore be reviewed by all stakeholders.
The Alberta Energy and Utilities Board (EUB) estimates that about 17,000 km of pipeline were abandoned or discontinued in Alberta as of April 1994. This number includes an estimated 3 600 km of orphaned abandoned pipelines. The majority of abandoned pipelines in Alberta are gathering lines 168.3 mm or less in outside diameter.
Regulatory requirements for pipeline abandonment vary across jurisdictions in Canada, and in many cases do not completely address associated long-term issues.
1.2 Review Initiatives
In 1984, several parties at a National Energy Board (NEB) hearing into the tolls of a major natural gas transmission pipeline company showed an interest in addressing the issue of negative salvage as it related to pipeline abandonment. As a result, the NEB issued a background paper in September 1985 addressing the negative salvage impacts of pipeline abandonment. The issue was not pursued again until 1990, when industry, the Alberta Energy Resources Conservation Board (now the EUB), and Alberta Environmental Protection (AEP) discussed the issue of pipeline abandonment while considering amendments to the pipeline regulations issued pursuant to the Pipeline Act (Revised Statutes of Alberta 1980). The issue was not resolved at that time, and was again raised in 1993 by the Alberta Pipeline Environmental Steering Committee, an industry, government, and public stakeholder group established to address pipeline related issues.
In October 1993, the Canadian Association of Petroleum Producers (CAPP) received the endorsement of the Alberta Petroleum Industry Government Environment Committee to establish a steering committee to oversee the issue of pipeline abandonment. Shortly thereafter, the EUB requested that CAPP and the Canadian Energy Pipeline Association (CEPA) organize a steering committee to resolve the concerns surrounding abandonment.
In April 1994, representatives from CAPP, CEPA, the EUB, and the NEB met to establish a pipeline abandonment steering committee. It was also decided at that time that separate subcommittees be struck to address the technical, environmental, legal, and financial aspects of pipeline abandonment. The technical and environmental subcommittees were the first to be formed and, together with the steering committee, were responsible for this discussion paper. The legal and financial subcommittees have not yet been struck.
1.3 Scope
This discussion paper is intended to apply to all buried metallic pipeline facilities falling within the scope of the CSA Z662-94 "Oil and Gas Pipeline Systems" standard, except for offshore pipelines. Many of the same issues and concepts (such as those relating to land use and pipe cleanliness) also apply to plastic and fibreglass pipelines. It addresses pipeline abandonment only (i.e. permanent removal from service), and does not consider pipeline deactivation (i.e. temporary removal from service). Likewise, this document does not address the abandonment of aboveground facilities associated with pipelines, such as stations or tank farms, or specific facilities such as underground vaults.
This paper addresses the technical and environmental aspects of pipeline abandonment. In order to complete the assessment, a review of the legal and financial aspects of pipeline abandonment needs to be undertaken. More particularly, the core issues of long-term liability and funding need to be addressed both in the context of orphaned pipelines and those with an identifiable owner/operator.
1.4 Abandonment Options
The two basic options that are considered in this paper are (i) abandonment-in-place and (ii) pipeline removal. In the former case, it is assumed for the purposes of this paper that cathodic protection of the pipeline is discontinued and that no other measures are taken to maintain the structural integrity of the abandoned pipeline (other than the potential use of solid fill material at roadway and railway crossing sites or other locations highly sensitive to ground subsidence).
As noted in Section 2, for any large-scale abandonment project it is unlikely that only one of these options will be employed. Rather, a project will usually involve a combination of pipe removal and abandonment-in-place along the length of the pipeline. A key factor influencing the choice between the two options is present and future land use.
It is further noted that the abandonment techniques presented are confined to those possible using currently available technology. While developments in pipeline removal and abandonment technologies were evaluated, no major improvements to the methods currently in use were discovered. However, as pipeline abandonments become more prevalent, improved abandonment methods will likely be developed.
1.5 Objective
The objective of this discussion paper is to assist the user in the development of a pipeline abandonment plan, a framework for which is provided in Section 2 of this paper. More particularly, the paper is meant to assist parties in making an informed decision between abandoning in place or through removal. Section 3 outlines the general technical and environmental issues that should be considered when abandoning a pipeline, while Section 4 elaborates on post-abandonment responsibilities. Site-specific issues should be addressed on a case-by-case basis.
The objective of creating an abandonment plan is to ensure that identified issues have been addressed and that the pipeline is abandoned in a way that provides a forum for meaningful stakeholder input and ensures that public safety and environmental stability are maintained.
1.6 Regulatory Requirements
The NEB is responsible for regulating interprovincial and international pipeline systems in Canada, while the individual provinces are responsible for regulating intraprovincial pipeline systems. Within each province, gathering, transmission, and distribution pipelines may be regulated by different agencies. For example, in Alberta the EUB regulates gathering and transmission lines as well as higher-pressure distribution lines (greater than 700 kPa), while lower-pressure distribution lines are regulated by Alberta Transportation and Utilities. AEP, through the Environmental Protection and Enhancement Act (EPEA), regulates conservation and reclamation activities for all three categories of pipelines.
In addition to the primary regulators, there may be other governmental agencies within each of the respective jurisdictions that may have an interest in the abandonment and reclamation of a pipeline. These other agencies may include local governments, especially in populated areas where pipeline abandonment may impact upon land uses.
In Alberta, the EUB sets the requirements for the abandonment of gathering and transmission lines. In addition to meeting the EUB's abandonment requirements, the pipeline right-of-way must be reclaimed to AEP standards. Reclamation certificates are issued by inspectors designated under EPEA. For removal projects that are classified as Class I projects,[1] the operator is required to obtain an approval under EPEA from AEP to ensure that proper conservation and reclamation occurs. For smaller projects, AEP's Environmental Protection Guidelines for Pipelines are to be followed during construction.
[1] A Class I pipeline is defined by the Activities Designation Regulation (AR 110/93) under EPEA as any pipeline that has an index of 2690 or greater, determined by mutiplying the diameter of the pipeline in millimetres by the length of the pipeline in kilometres (e.g. 168.3 mm x 16 km = 2693).
For federally regulated pipelines, approval to abandon a pipeline must be granted by the NEB and pipelines must be abandoned in accordance with the requirements of the NEB's Onshore Pipeline Regulations. These regulations are in the process of being revised, and future regulations will likely require that applications for pipeline abandonment be treated on a case-by-case basis.
A summary of the current regulatory requirements for pipeline abandonment across Canada has been included as Appendix A.
Section 2 - Developing an Abandonment Plan
This paper addresses the common issues that pipeline abandonment plans should address regardless of regulatory jurisdiction. It is intended to assist a company in the development of an abandonment plan through the recognition of the general issues which result from the abandonment of a pipeline and by providing the means to address those issues.
In practice, the decision to abandon in place or through removal should be made on the basis of a comprehensive site-specific assessment. In this context, the analysis presented in this paper has limitations in that all site specifics could not possibly be addressed, particularly in relation to potential environmental impacts or impacts on present and future land use.
The development and implementation of a pipeline abandonment plan that will minimize impacts to the environment and land use and be cost-effective requires many activities similar in scope to the planning or installation of a new pipeline. For any large-scale abandonment project, it is unlikely that any one abandonment technique will be employed. Once the principal technique has been chosen, therefore, the owner/operator should assess on a site-specific basis whether an alternate approach should be followed for selected segments of line.
The abandonment project schedule should provide an opportunity for meaningful input into the planning process by the affected public, as defined by the scope of the project. It is especially important that landowners and land managers have a central role in this process.
The development of an abandonment plan should be initiated by reviewing the general requirements of the regulatory jurisdiction(s) under which the pipeline is operated. Beyond the requirements of the principal regulatory agencies, other legislation may affect the particular abandonment project. For example, municipal requirements and federal legislation such as the federal Navigable Waters Protection Act or the Fisheries Act may affect the abandonment options.
It is also critical that easement agreements be reviewed, as their terms and conditions may bear on the abandonment decision-making process.
The development and implementation of an abandonment plan consists of at least the following seven steps:
- review prevailing regulatory requirements applicable to the abandonment project;
- compile all relevant information on the pipeline system, including easement agreements;
- analyze by segment taking into account the factors addressed in Section 3 of this paper, including present and future land use;
- develop the abandonment plan in consultation with stakeholders (such as landowners, government authorities, and other directly affected parties), incorporating the information compiled in the above steps;
- secure regulatory and landowner approvals as required for the pipeline abandonment and site reclamation;
- implement the abandonment plan, the scope of which should include post-abandonment responsibilities (addressed in Section 4); and
- secure final regulatory release.
A proponent undertaking an abandonment plan should follow these six steps, recognizing that site-specific conditions may require additional steps in the development of the plan.
Please refer to the next page for a flowchart of the abandonment planning process and to Appendix B for a detailed abandonment checklist.
Figure 2-1
Diagramme illustrant la cessation d'exploitation d'un pipeline
Section 3 - Technical and Environmental Issues
3.1 Issue Identification
Abandonment issues arise from the need to address public safety, environmental protection, and future land use. An initial scoping exercise was carried out to identify the various technical and environmental issues associated with abandonment. Following the development of a detailed issues list, field studies of existing abandoned facilities were performed to verify the issues. In some cases, detailed studies were commissioned in order to better understand the effects and interactions of certain issues.[2]
[2] (Refer to the Bibliography in Appendix E for a list of the studies, copies of which are available for public viewing in the libraries of CAPP, CEPA, the EUB, and the NEB.)
The primary issues that were identified, and which are addressed in this section, are as follows:
- land use management;
- ground subsidence;
- soil and groundwater contamination;
- pipe cleanliness;
- water crossings;
- erosion;
- utility and pipeline crossings;
- creation of water conduits;
- associated apparatus; and
- cost of abandonment.
It was determined that most issues are not unique to the abandonment phase of the pipeline life-cycle, but could involve an altered scope, varied timeline, or additional stakeholders when compared to the issues of pipeline installation and operation. In order to responsibly abandon a pipeline, the operator must consider all of the issues and determine how they relate to the specific pipeline under consideration, in addition to addressing stakeholder concerns and incorporating collected input.
In any abandonment project, it is possible that a combination of both the abandonment-in-place and removal options would be used, based on site-specific requirements. Thus, it is important that all aspects of the abandonment issues be considered. As the following discussion illustrates, the abandonmen-in-place option does not eliminate the need for land disturbance or field activity, while pipeline removal need not encompass the same level of disturbance or activity as that of pipeline construction.
3.2 Land Use Management
Land use is the most important factor to consider in determining whether a pipeline section should be abandoned in place or removed. Therefore, an understanding of the current and potential land uses along the pipeline right-of-way is essential to making informed decisions on available abandonment options.
Of particular concern with respect to land use management are areas sensitive to land disturbance, such as native prairie, parks and ecological reserves, unstable or highly erodible slopes, areas susceptible to severe wind erosion, and irrigated land, particularly flood irrigation systems. Additionally, land improvement activities such as the installation of drainage tile or other drainage systems, landscaping, and permanent structure installations could be affected by a proponent's decision to abandon a line.
Future land use should be considered because a pipeline abandoned in place could become a physical obstruction to development, such as excavation for foundations, pilings, or ongoing management practices such as deep ploughing or the installation of sub-drains. It is critical that input be gathered from appropriate sources such as landowners, land managers, lessees, and municipal agencies to support the decision to abandon in place. In addition, sufficient documentation must be kept to allow for detailed location information for future developers or owners.
As noted in Section 2, the decision to abandon in place or through removal should be made on the basis of a comprehensive site-specific assessment. In this context, the land management characteristics that may be better suited to pipeline abandonment-in-place include, but are not limited to:
- parks and natural areas;
- unstable or highly erodible surfaces;
- water crossings;
- flood irrigated fields;
- road and railway crossings;[3]
- foreign pipeline crossings;
- extra depth burial of pipe (i.e. depth well in excess of one metre);
- native prairie and native parkland;
- forest cut blocks;
- designated waterfowl and wildlife habitat; and
- areas exhibiting poor and/or limited access.
[3] (as detailed in Section 3.8, consideration should be given to filling pipeline sections abandoned in place underneath roadways and railways with a solid material such as concrete in light of potential ground subsidence impacts.)
The key environmental protection measures to be considered when a pipeline is to be abandoned in place are as follows:
- minimal disruption to ongoing or future land management activities;
- a complete and documented pipeline cleaning procedure;
- the clean-up of any spills or contaminated sites to prevailing regulatory requirements;
- a revegetation strategy to achieve pre-abandonment conditions, keeping erosion control and soil stability as a priority;
- topsoil conservation for all areas disturbed during the abandonment process;
- reclamation of all site access roads, including those which had been developed for the operational phase of the pipeline and any opened or developed for abandonment activity;
- documented as-built information for future reference;
- application of sight blocks where appropriate (e.g. recreational areas and wildlife habitat); and
- a monitoring program acceptable to all affected parties to ensure a process to complete remediation.
Proper environmental protection measures should be implemented, including appropriate soil handling procedures, timber management, contingency plans (e.g. for spills and wind or water erosion), protection of cultural features, weed control, and site reclamation. For example, in Alberta, a Conservation and Reclamation (C&R) report may be required by AEP for pipelines which were constructed before the C&R regulations came into effect.
Prior to the commencement of field activity, reclamation criteria should be agreed upon by the owner/operator, regulatory authority, and landowner. The reclamation program will normally be designed to ensure that the condition of the right-of-way land surface is made at least equivalent to that existing just prior to the commencement of abandonment activities, and as close as circumstances permit to the condition of the land that existed prior to pipeline installation, and may entail:
- removing, storing, and replacing topsoil;
- soil contamination analysis and-clean up, if required;
- contouring disturbed land to control drainage;
- seeding affected areas to prevent erosion and establish vegetation;
- removal of all structures to a minimum depth of one metre below final contour elevation;[4]
- roaching and/or compacting excavated areas to compensate for future settlement; and
- site-specific environmental requirements (e.g. reforestation).
[4] (In areas where circumstances such as special farming practices or nearby urban development exist, consideration should be given to removing structures more than one metre below the final contour elevation.)
As noted in Section 4, a right-of-way monitoring plan should be developed to ensure that reclamation efforts are successful and that no problems arise.
3.3 Ground Subsidence
3.3.1 General
The long term structural deterioration of a pipeline abandoned in place may lead to some measure of ground subsidence. This is a primary issue to consider for larger-diameter pipelines because of potential environmental and safety concerns. More particularly, ground subsidence could create the potential for water channelling and subsequent erosion, lead to topsoil loss, impact on land use and land aesthetics, and/or pose a safety hazard.
The acceptable subsidence limits and the potential factors affecting those limits are significant areas requiring attention in the development of any abandonment plan. Erosion may cause direct siltation to a watercourse, or cause slope failures and subsequent siltation. Where potential siltation is an issue, proponents must be prepared to deal with fisheries protection measures to remain in compliance with provincial and federal legislation.
The rate and amount of ground subsidence over time is difficult to predict as it depends on a complex combination of site-specific factors, such as the corrosion mechanics in the vicinity of the pipeline, the thickness and diameter of the pipeline, the quality of the pipeline's coating, burial depth, soil type, the failure mechanics of the pipeline material, and soil failure mechanics.
Given the absence of previously documented research, studies were commissioned on corrosion and soil mechanics in an attempt to establish the connection between pipeline corrosion, the structural deterioration of pipe, and the resultant ground subsidence that might be observed. Summaries of these studies and the conclusions that were reached follow.
3.3.2 Pipeline Corrosion
The corrosion consultant's report addressed the mechanism of corrosion leading to ultimate structural failure of a pipeline. The report stated that the rate of corrosion of an abandoned pipeline can vary significantly due to the many factors which must be present for corrosion to take place. Corrosion of buried pipelines occurs through an electrochemical reaction that involves the loss of metal in one location (called the anode) through the transfer of the metal ions to another location on the pipeline (called the cathode). The rate of metal transfer depends on a number of factors such as the quality of the pipeline coating, soil aeration (which supplies oxygen to the pipe to allow the corrosion process to occur), types and homogeneity of soils, soil moisture, and electrical factors which create the potential differences for a corrosion cell to be established.
The corrosion of a coated pipeline is normally restricted to those isolated areas where there are defects in the coating or where the coating has become disbonded from the pipe. Corrosion can be expected to be almost negligible in areas where the coating integrity is intact. Based on his experience, the consultant observed that coating holidays or disbondment occur on less than one percent of the length of most pipelines. Pipeline corrosion in most cases occurs as localized pits, or spiral corrosion areas, which eventually result in random perforations throughout the length of the pipeline. It is extremely rare for corrosion to cover large areas of pipeline, rendering a long segment of the pipeline susceptible to sudden and complete structural failure.
To illustrate typical corrosion rates, the consultant used an example of a 323.9 mm O.D. pipeline in soils commonly found throughout Alberta and estimated that penetrating pits would occur in the range of 13 to 123 years. Based upon the slow rate of pitting corrosion that would occur in most cases, complete structural failure is not likely to occur for decades or even centuries. Furthermore, given the non-uniform nature of the corrosion process, it can be concluded that it is highly unlikely that significant lengths of the pipeline would collapse at any one time.
3.3.3 Soil Mechanics
The soil mechanics report indicated that there has been no documented incidence of ground subsidence due to pipeline structural failure. In order to predict soil reaction to pipeline structural failure, the consultant modelled its review on shallow mining and tunnelling research and documented case histories. The focus of the study was to estimate possible surface subsidence that could be attributed to the complete failure of tunnels of equal diameter and depth as the pipelines being modelled. This represented a worst-case scenario, since as noted earlier a complete pipeline collapse of any significant length is considered highly improbable.
The report employed two different theoretical soil modelling techniques, the Rectangular Soil Block and the Active Soil Wedge, to reflect the most common types of soils that may be encountered. The ranges of subsidence calculated for varying sizes of pipelines provided an approximation of the impacts that a significant pipeline collapse would have on soils. The analysis indicated that ground subsidence associated with the collapse of pipelines up to 323.9 mm in diameter at typical burial depths would be negligible. The analysis further indicated that while there would be some degree of subsidence associated with larger pipeline sizes, it may be of sufficiently small scale so as to be in a tolerable range.
3.3.4 Field Investigation Program
In order to validate the conclusions of the technical reports, the subcommittees undertook to document the ground subsidence of known abandoned pipelines.
As a first step, the subcommittees searched the EUB's records and identified pipelines 168.3 mm or larger in diameter that had been abandoned in place. Questionnaires were forwarded to the owners/operators of some of those lines, requesting information on pipeline diameter, coating type, year abandoned, whether cathodic protection had been removed, and ground subsidence observations (reference Appendix C for copy of questionnaire). The responses to the survey, as well as industry discussions, did not reveal any instances of observed subsidence.[5]
[5] (As indicated in Appendix C, all of the survey results gathered by the subcommittees are available for public viewing in the libraries of CAPP, CEPA, the EUB, and the NEB.)
3.3.5 Summary of Findings
The analyses indicated that the structural failure of an abandoned pipeline due to corrosion may take many decades, and that significant lengths of the pipeline would not collapse at any one time due to the localized nature of the pitting process. Furthermore, the analyses indicated that, even if the worst-case scenario of uniform and total structural collapse was realized, ground subsidence would be negligible for pipelines up to 323.9 mm in diameter.
The degree of subsidence associated with larger-diameter pipelines is highly dependent on pipeline diameter, depth of cover, and local soil conditions, but can be expected in many cases to be in a tolerable range. It should be noted that tolerance to soil subsidence is in itself a site-specific issue, as it depends on land use and the local environmental setting. Any pipeline owner/operator considering the abandonment-in-place of a larger-diameter pipeline should therefore conduct a site-specific analysis in order to evaluate both the degree and tolerability of any long-term subsidence that might be expected. Such analyses should take into account the potential for heavy vehicular loadings (e.g. farm equipment or logging trucks).
On the basis of the foregoing, it is suggested that ground subsidence associated with the structural failure of pipelines abandoned in place will not usually be a critical issue. This conclusion was corroborated by the industry survey referred to in Section 3.3.4. In areas where no settlement is allowed, either by regulation or agreement (such as at highway crossing sites, as further explained in Section 3.8), the option would exist to fill the pipeline with an approved solid material such as concrete or sand.
In terms of follow-up on this issue, it is suggested that tolerance criteria be developed and that the industry survey referred to in this paper be complemented with a field observation program. Scale modelling could also be performed to confirm the theoretical ground subsidence calculations.
3.3.6 Subsidence as a Result of Pipeline Removal
The physical act of removing a pipeline is essentially the reverse operation of pipeline construction and involves topsoil removal, backhoe excavation of the subsoil to a depth at least even with the top of the pipe, pipe removal, backfilling and compaction of the trench, replacement of the topsoil, and revegetation measures.
During pipeline construction, a roach consisting of subsoil overlaid with topsoil is usually employed to compensate for the settlement that will occur as the ditch line settles. The same strategy can be employed at the abandonment stage to avoid the need for reclamation in future years due to settlement and erosion. In general, if extra topsoil or soil materials are required for this operation, it could be recovered from areas immediately adjacent to the pipeline right-of-way. For older pipelines built before mandatory soil conservation, this is where extra topsoil or soil materials may have been disposed. Further surveys or examinations of topsoil depths and soil volumes may be required to identify these potential borrow areas.
Without the concern of compaction damaging the pipeline, a company may undertake a more rigorous compaction of the soil being replaced in the ditch following pipe removal than after backfilling for new construction. Additional compaction may also result in less topsoil handling and, therefore, fewer impacts due to the decreased need to strip topsoil to accommodate the feathering out of subsoil material caused by the excavation.
3.4 Soil and Groundwater Contamination
The abandonment plan should address the potential for contamination associated with the abandonment activities, as well as the need to eliminate any contamination that may already exist, and include the appropriate pipe cleaning or pigging procedure. Any contamination noted prior to abandonment activity should be cleaned up to the applicable regulatory standards prior to full project disturbance, unless it is more economically efficient to include the cleanup in the scope of abandonment activity and it can be demonstrated that environmental damage will not be amplified.
In order to gain additional insight into the issue of contamination, a study was commissioned into the types and quantities of contaminants that might be released from pipelines abandoned in place.
The potential sources of contamination were identified as:
- the substances produced from the reservoir in the hydrocarbon stream and deposited on the walls of the pipeline;
- treatment chemicals which could enter the pipeline and be deposited;
- the line pipe and associated facilities;
- pipeline coatings and their degradation products;
- historical leaks and spills of product that were not cleaned to current standards; and
- possible PCB contamination, if PCBs were used in the pump or compressor lubricants at some point in the history of the pipeline.
The quantity of residual contaminants can be expected to decrease as the product moves from the wellhead through the gathering, processing, and distribution systems. Traditionally, oil pipelines contain a greater volume of wax and scale than do natural gas pipelines, but this is dependent on the circumstances of the particular production field. The study concluded that the effectiveness of pipeline pigging and cleaning procedures prior to abandonment was the most critical determinant of the potential quantities of residual contaminants.
The subject of pipeline cleaning is addressed at length in Section 3.5 and Appendix D. An operator should become familiar with prevailing regulatory standards for soil and groundwater, as these standards may dictate the minimum acceptable level of pipe cleanliness. Sound environmental protection practices should be observed throughout the pipeline cleaning process, such as the use of properly engineered containment and storage for all collected material, proper labelling, disposal processes conforming to local regulations, and effective spill contingency plans. Detailed documentation should be recorded on the results of the cleaning process or the clean-up of a contaminated site.
Operators should also have an understanding of the composition of pipe coatings and their associated characteristics to assess any potential risk that may be derived from abandoning the pipeline in place. For example, pipeline coatings containing asbestos should be handled through special means by trained personnel. It has been suggested that if pipe coating compounds would be accepted at local landfills, then abandoning a pipeline with the same compounds in place may not be a concern, depending on site conditions and concentration levels. Presently, limited information exists regarding the long-term decomposition of pipeline coatings. However, it can be assumed that as the coating adhesive degrades, or is consumed by soil organisms, coatings will eventually disbond and contribute to the corrosion process.
Many of the same contamination prevention measures to be employed for abandonment-in-place also come into play in the context of pipeline removal. Of prime importance is the need to clean the pipeline to accepted standards prior to the commencement of the removal operation, and the employment of measures to prevent spills of the substances collected as a result of the cleaning process. Collection trays should be used during the pipe cutting operation to catch any residual fluids.
During pipe removal, proper soil handling measures must be implemented to ensure topsoil conservation.
In addition to the pipeline itself, the dismantlement of any connected facilities should be carried out such that the potential for contamination is controlled by proper containment and storage for disposal at an approved facility.
3.5 Pipe Cleanliness
3.5.1 Cleanliness Criteria
In light of potential contamination concerns, the cleanliness of the pipeline is an issue for both abandonment techniques. Although responsible cleaning procedures have been defined and are discussed in detail in Section 3.5.2 and Appendix D, the question of "how clean is clean" has not been resolved. In addition, the question remains as to whether pipe that will be removed should be subject to the same cleanliness criteria as pipe that will be left in place. It should be assumed that pipe that is to be removed should be cleaned to a level where any remaining residues will not cause harm in any future intended use of the pipe. Removed pipe that may eventually be put to some alternative use (e.g. pilings) may require more study to determine the appropriate cleanliness requirements for the future use. For pipe that is targeted for disposal, existing disposal or landfilling guidelines will determine the required cleanliness of the pipe.
For pipe that will be abandoned in place, the issue of pipe cleanliness is related to corrosion and the creation of water conduits. Eventually the pipe will corrode until perforated and, aided by the destructive forces of the freeze-thawing of infiltrated water, the structural integrity of the pipe will suffer. Whether the rate of deterioration will be greater than the life of the contaminants left as internal residue of the pipe is unclear. Similarly, an issue remains over the rate and structural location of any corrosion, in that it may allow water to infiltrate the abandoned pipe and transport pipe residues to some other exit point.
3.5.2 Cleaning Procedures
The pigging procedure used during the final operating stages and during evacuation of the pipeline is critical in preparing the line for abandonment. The study on contaminants concluded that the small quantities of hydrocarbons left in the line after a concerted pig cleaning effort will not result in any significant environmental concerns.
The factors impacting the effectiveness of any pig cleaning procedure will vary with each pipeline. Cleaning programs must therefore be customized to the specific circumstances of the pipeline under consideration for abandonment. For guidance purposes, Appendix D sets out general cleaning considerations and describes typical cleaning methods for an oil pipeline in a medium duty service [6] or for a pipeline carrying relatively dry natural gas. Operators planning a pigging program for a specific line should consider these guidelines as a starting point only. The abandonment of pipelines carrying products other than the two noted above require customized pigging procedures to ensure proper cleaning. Care should be taken in all cases to properly contain and dispose of pigged effluent.
[6] Medium duty service refers to relatively wax and direct free operation with a scraping program undertaken occasionally to move along anything collected or adhering to the pipe wall.
A pipeline to be abandoned in place should be left such that no solids or waxy build-up are visible at any point along the pipeline as observed through standard pipe openings such as opened flange or sample connections and the contents have been cleaned out to the extent that no more than a thin oily film on the inside pipe wall surface can be detected by feel or sight. Sour liquid or natural gas pipelines should be checked to confirm that H2S levels are below acceptable limits.
Pipe cleaning is also of critical importance in the context of pipeline removal, given the desire to minimize the risk of soil and groundwater contamination during the removal process and the hazards associated with pipe removal (e.g. health and flammability hazards of exposed vapours). Cleanliness considerations relating to the future intended use or disposal of the pipe should also be taken into account, bearing in mind that supplementary cleaning techniques may be employed once the pipe has been removed from the ground.
Cleaning effectiveness can be determined by taking pipe coupons and swabs of any film found on the inside of the pipe and analyzing them for contamination, using cutout means such as hot tapping or line cutouts.
After allowing some time for the collection of remaining liquids in low areas (minimum one week suggested), the pipeline should be excavated at random low areas. A minimum of one excavation site per scraper trap or 80 km interval is suggested. However, in undulating areas multiple excavation sites may be required. Excavation sites should be chosen to avoid environmentally sensitive areas and to minimize clearing associated with the opening of access roads. If the examination of the inside wall shows that the cleanliness criteria has been met, the cleaning task can be considered complete.
3.6 Water Crossings
The effect of pipelines on water crossings is an important issue at any stage of a pipeline project. This issue is a significant social consideration due to the visibility of crossing activities, the importance of fisheries resources, public use of waterways, the sensitivity of the resource, and the fact that waterways are an important cultural and historical feature of the land.
There are many factors to consider in deciding whether a section of pipeline crossing a water body or wetland (e.g. muskeg, swamp, or flood plains) should be abandoned in place or removed. More specifically, the risks associated with abandoning the pipeline in place, including the potential for contamination and pipe exposure, have to be weighed against the cost and environmental impact of removal.
These trade-offs should be assessed on a site-specific basis, taking into account the size and dynamics of the water body, the design of the pipeline crossing, soil characteristics, slope stability, and environmental sensitivities. While these issues must be evaluated, in most cases it can be expected that abandonment-in-place will be the preferred option.
If the pipeline crossing is to be abandoned in place, the pipe should be left in as clean a state as possible to minimize the potential for contamination of the waterbody should the eventual perforation and failure of the pipe allow any internal residues to escape. As described in Section 3.9, the strategic placement of caps and plugs will also help mitigate this concern by interrupting the movement of potential contaminants through the abandoned pipe.
The risk of pipe exposure is two-fold. First, the pipeline could become exposed if the overlying soil is gradually eroded or washed away because of the dynamics of the water body (e.g. stream bank migration, scour, or flood conditions). Secondly, an empty pipeline crossing a water body or wet area could float toward the surface if buoyancy control mechanisms fail (e.g. if concrete saddle weights slide off). In either case, the owner/operator should assess the probability that the pipeline could become exposed and the impacts that exposure would entail. If the risk of flotation is a concern, it could be addressed by either perforating the line following an appropriately sensitive line cleaning program to allow it to fill with water or by filling the line with concrete or some other solid material. In the case of the former option, plugs and caps should be used to prevent water migration through the pipeline.
If applicable, the risks associated with abandoning a pipeline in place which runs parallel to an operating pipeline at a water crossing should also be assessed.
If the pipeline is to be removed in whole or in part, the issues would be similar in many ways to those associated with initial construction across the water body or wetland. More specifically, many of the same construction techniques and environmental protection measures would apply. Aspects to address include fisheries resource timing sensitivities, habitat protection, sediment control, vehicle and equipment crossing methods, backfill material specifications and source, erosion control measures (both short term and long term), and bank restoration. Damage to any existing bank stabilization structures or destabilization of previously stable banks should be considered.
It is crucial that the pipe be as clean as possible prior to excavation to minimize the potential for contamination of the waterbody should the pipe be damaged and a spill occur during the removal procedure. Blinding off the ends of the section being removed is recommended to prevent contamination by any remaining traces of material.
3.7 Erosion
Soil erosion is a concern during all phases of the pipeline life-cycle, particularly as it relates to slope stability. Leaving a pipeline in the ground may entail a certain amount of activity along the right-of-way to ensure responsible abandonment, such as excavations to confirm cleaning quality and the installation of caps or plugs. The potential impact of the ensuing right-of-way disturbance will vary greatly with the geographic location of the activity. For example, a forest area "duff" layer may not be as susceptible to erosion and slope instability as a region of native prairie topsoil.
If the pipe is to be removed, erosion and slope stability concerns will be similar to those for pipeline construction. For example, traffic, soil compaction, and the wind and water erosion of disturbed soil may be of concern. In addition, the pipeline may have become a structural support to many slopes over time, and its removal may affect the integrity of the slope.
When developing an abandonment plan, the pipeline owner/operator should review any erosion remediation that had occurred over the operating life of the pipeline. If erosion control measures have been regularly required at specific locations, the owner/operator should determine if it would be appropriate to implement longer term erosion control measures.
If the abandonment activities necessitate disturbing erosion-prone areas including slopes, protection measures designed to current standards should be implemented. In addition, the integrity and effectiveness of any existing ditch plugs, sub-drains, berms, or other installations should be reviewed.
It is usually more appropriate to abandon pipe at unstable slopes in place, due to the potential requirement for extensive remediation if the pipeline is removed. On sensitive slopes, the use of sight blocks or other measures should be considered to discourage use of the right-of-way. In areas where the right-of-way has been traditional access for recreational users or hunters, the operator should attempt to reach an agreement with the land manager for ongoing remediation, if necessary.
In areas where slope movement was being monitored during the pipeline's operating life, the monitoring program should be re-evaluated and continued, if warranted. Temporary access roads to slopes should be reclaimed as appropriate.
Protective measures to be considered when removing a pipeline from a slope would be similar to those used during pipeline construction. The integrity of the slope must be maintained during the removal activities, as well as after the line is removed. If the removal calls for spot excavations (bellholes) instead of an open ditch removal, the stability of the entire slope, as well as the region surrounding the bellholes, should be evaluated. Re-installation of diversion berms and ditch plugs to prevent water channelling may be required.
Development of the abandonment plan should include consultations with other pipeline owners/operators that may be affected by right-of-way disturbances on the slope. In addition, regulators and landowners should be consulted in order to determine an appropriate period for right-of-way monitoring after the pipeline is removed. A typical monitoring period would be two years. Revegetation programs should consider the inclusion of a species that is quick to establish in the revegetation mixture, as this may help to provide short term erosion control; however, the environmental effect of introducing a non-native species must be considered. Regulatory/landowner approval of the seeding mixture would likely be required. A weed control plan should be initiated during the pipe removal process to address potential concerns immediately following surface disturbance.
3.8 Road, Railway, and Utility Crossings
All crossings associated with a pipeline that is being abandoned must be addressed in an appropriate manner. Of particular importance are the agreements relating to the crossings of railways, primary and secondary highways, roads, other pipelines, power lines, and communication lines, and the constraints they may place on the abandonment process.
The parameters to be considered in selecting an abandonment technique for a crossing site include the line diameter, installation details (including burial depth), subsidence tolerance, impact of excavation, impacts on other cathodic protection systems (e.g. for crossings of other pipelines), and long term development plans. Special consideration should be given to the sensitivity of roadway and railway crossings to slight ground depressions that could result from any abandonment related subsidence. The potential may also exist for disruption to crossing traffic, both during and as a result of the pipeline abandonment. As a result, more stringent abandonment requirements may be imposed, such as filling the pipeline at the crossing site with concrete or other approved material. Similarly, cased crossings may require a solid fill even if the carrier pipe is removed.[7]
[7] If the carrier pipe remains in situ, both it and the casing annulus may require a solid fill (need should be assessed on a site-specific basis.)
The proper notification and location of the pipeline or utility being crossed is essential to maintaining a safe working environment. Operators of utilities and other pipelines may have established plans or expectations that may affect the design and timing of the abandonment. Utility crossing or pipeline crossing locations may be of concern when a pipeline is removed, due to the loss of support for the remaining facility, or the interference of the abandonment operation or the abandoned pipeline with the operation of the crossed utility or pipeline. Thus, discussions with utility and other pipeline companies will add value to the resulting abandonment plan and initiate protection planning.
The main steps of the abandonment evaluation and implementation process for any particular crossing site are as follows:
- review the existing crossing agreement and determine if there are any terms and conditions relating to abandonment-in-place or pipeline removal;
- establish communications with the utility or pipeline being crossed and negotiate terms and conditions (both technical and legal) to abandon the pipeline in place or remove the pipe;
- amend the existing crossing agreement to address the terms and conditions of the abandonment plan;
- notify all affected parties about abandonment activities and responsibilities;
- ensure that necessary approvals (e.g. from regulatory authorities, the utility being crossed, and the landowner) are obtained and kept on record;
- obtain proper location and identification of pipelines and utilities in the area using agencies such as Alberta First Call prior to commencing removal activities, and alert landowners to the activities taking place;
- file the necessary permanent records of the pipeline abandonment plan with interested parties (including pipeline regulatory authorities, provincial one-call systems, environmental groups, land titles, pipeline registers, and the affected crossing parties); and
- in the case of abandonment-in-place, ensure that the inspection requirements for the crossing are part of the post-abandonment monitoring plan.
3.9 Creation of Water Conduits
The potential to create water conduits as a result of the abandonment process is of concern as it could lead to unnatural drainage and material transport. This issue is primarily of concern when a pipeline is abandoned in place, since water will eventually infiltrate the pipe through perforations in the pipe wall caused by corrosion.
Unless water pathways through the pipeline are interrupted, this could lead to the unnatural drainage of areas such as muskegs, sloughs, or marshes, thus affecting the natural balance of the ecosystem. Likewise, a previously stable low area could be flooded by volumes of water exiting from a perforated pipeline. This issue can be related to the concern for contamination and the protection of wetland systems. If water infiltrates the pipeline, the potential exists for that water to carry any residual contaminants left in the abandoned pipeline to some point of exit. The point of exit could be a watercourse, thereby contaminating the watercourse if contaminant levels are sufficiently great in volume and concentration at the point of exit. The possibility of soil contamination may also exist, depending on the nature of the contaminant transported through the pipeline.
Plugs should be installed at appropriate spacings to ensure that changes in surface and ground water conditions will not result in water flow through the pipeline. When identifying locations for the plugs, consideration should be given to pipeline access during the placement of the plugs and the resulting effects of the ground disturbance. Where the pipeline crosses a wet area, a plug should be placed just downstream of the wet area, to prevent its drainage, and also at an appropriate location upstream of the wet area, to prevent the wet area contamination by water flowing along the pipeline. The plugs should be long enough so that corrosion downstream of the plug will not result in water entering the pipe.
On slopes, water could seep into the pipeline through perforations and exit at unacceptable locations such as agricultural areas or areas where excessive erosion would result. The water should be allowed to exit at frequent intervals and at preferred locations in order to minimize potential impacts from the flow of water and the disruption to natural drainage patterns. Typical locations for plugs are provided in the following table.
Table 3-1 Recommended Plug Locations |
|
---|---|
Terrain Feature | Plug Locations |
waterbodies/watercourses | above top of bank |
long inclines (>200m), river banks | at top and bottom of slope and at mid-slope for long inclines |
flood plains | at boundaries |
sensitive land uses (e.g. natural areas, parks) | at boundaries |
near waterfalls, shallow aquifers, groundwater discharge and recharge zones, marshes, sloughs, peatlands, highwater table areas | at boundaries and should include an adequate buffer zone |
cultural features (population centres) | at boundaries |
The plugs should adhere to the pipe, be impermeable and non-shrinking, and able to resist deterioration. Examples of suitable materials are concrete grout or polyurethane foam. The use of impermeable earthen plugs may also be a viable option.
In the case of pipeline removal, water pathways through the uncompacted pipeline trench material must be prevented or interrupted. The principles governing the locations of trench breakers are the same as those governing the locations of plugs for pipelines abandoned in place.
3.10 Associated Apparatus
The development of any abandonment plan should also give consideration to the disconnection, removal and disposal of apparatus associated with the pipeline, including:
- aboveground valve sites and manifolds;
- underground valve sites and manifold piping, as well as protruding elements such as valve topworks;
- underground tanks;
- pipeline scraper traps;
- pipeline risers;
- line heaters;
- drip pots;
- pipeline access culverts (e.g. for tie-ins, valves, liners, etc.);
- cathodic test posts, fink stations, rectifier sites, and ground beds (to a depth of one metre);
- aboveground tanks and containment berms;
- access roads, gates, and fences;
- anchor blocks and steel piles; and
- miscellaneous apparatus such as radio antennae, buildings, fencing, wiring, electrical equipment, and slope monitoring equipment.
It is recommended that all surface and subsurface apparatus (including signage) along the route of a pipeline that is to be abandoned through removal also be removed as part of the abandonment process.
For pipeline sections that are to be abandoned in place, it is recommended that all surface apparatus as well as subsurface apparatus to a depth of at least one metre be removed, with the notable exception of signage identifying the location of the buried line pipe (i.e. line markers and aerial markers). This applies to apparatus located on operator owned land as well as apparatus located on pipeline-specific surface leases on public or private land.
Any apparatus that is left in place should be secured and properly marked and recorded, and should not pose a hazard to people, equipment, or wildlife and livestock.
3.11 Cost of Abandonment
The cost of abandoning a pipeline may be quite significant. There is a broad scope of costs to consider, from the traditional costs associated with abandonment to more intangible items such as a company's public image and the costs of environmental consequences. In order to make responsible decisions regarding abandonment, all of these costs must be considered.
The cost of abandoning a pipeline will depend on the resources required to complete the work, the value of any salvaged material, the extent of remediation and reclamation work required (as well as any associated security requirements [8]), and many other factors. Proponents should also consider the costs associated with monitoring a site and potential future remediation, as well as the consequences of the abandonment activities and any legal issues that may arise. Changes in the regulatory environment may also give rise to unanticipated abandonment costs to ensure "no responsibility by the owner/operator" after a prescribed monitoring period.
[8] For example, in Alberta, if an approval under EPEA is required for the abandonment of a Class 1 pipeline, security is to be provided to AEP before the approval is issued. The security amount is determined using an estimate of the cost of reclamation.
Section 4 - Post-Abandonment Responsibilities
Once a pipeline has been abandoned, the owner/operator may retain a number of responsibilities. More particularly, the owner/operator may be responsible for ensuring that the right-of-way and any facilities left in place remain free of problems associated with the abandonment. For that reason, a right-of-way monitoring program should be included in the post-abandonment plan and accounted for in the abandonment budget.
Monitoring plans will vary from case to case, depending on the location and size of the pipeline, the land use, and the features of the terrain traversed by the right-of-way (such as water crossings or slopes). When developing a monitoring plan, the effects of each abandonment issue described in Section 3 should be thoroughly examined for each specific segment of the pipeline being abandoned. Specific monitoring requirements should be included for potentially sensitive areas.
Right-of-way maintenance should also be considered in the post-abandonment monitoring plan and factored as necessary into the abandonment budget. As noted in Section 3.2, the reclamation program will normally be designed to ensure that the condition of the right-of-way is made at least equivalent to that existing just prior to the commencement of abandonment activities, and as close as circumstances permit to the condition of the land that existed prior to initial pipeline installation. The degree to which the right-of-way has to be maintained in that state depends largely on land use and environmental sensitivities. For pipe left in place, the owner/operator would normally remain responsible for the maintenance of signage.
Additionally, the owner/operator may be responsible for maintaining post-abandonment information about the pipeline. This information should be recorded in a post-abandonment log book, so that it is available when needed and can be turned over to an alternate responsible authority if required by future regulations. The post-abandonment log book should contain:
- any regulatory permits and conditions attached to permits (including reclamation certificates);
- full particulars on any pipeline facilities abandoned in place, including a physical description, location and depth of cover, plug locations, and details of any sections filled with a solid material;
- copies of all past crossing agreements;
- records of post-abandonment aerial surveillances;
- records of any slumping over the pipe, or water flow through the pipe, that was noted during post-abandonment monitoring;
- records of any changes in pipeline state from the original abandonment plan (e.g. if pipe sections abandoned in place are subsequently removed);
- records of any remedial work performed on the pipeline after abandonment; and
- records of any areas that become contaminated after the abandonment and reclamation work is complete.
The owner/operator will also be responsible for notifying landowners, municipal authorities, and other affected parties (such as one-call associations) of the abandonment of the pipeline. Any input provided by these groups should be recorded in the post-abandonment log book.
Finally, any pipeline abandoned in place should remain part of any provincial one-call program, so that third parties can be advised whether the lines they wish to have located are active or abandoned.
In closing, a major issue still to be addressed is the question of who would assume responsibility if the owner/operator becomes insolvent. In this regard, industry has established a fund in Alberta to cover the cost of reclamation and abandonment of orphaned oil and gas wells and certain associated pipeline facilities.
Appendix A - Current Regulatory Requirements
Refer to the following three tables for an outline of the current regulatory requirements for pipeline abandonment across Canada.
JURISDICTION | AGENCY | LAW | SCOPE | ABANDONMENT/ REMOVAL CLAUSE | ACTION REQUIRED |
---|---|---|---|---|---|
FEDERAL | National Energy Board | National Energy Board Act | All pipelines | Part V, Para. 74(d) | Leave of the Board |
Onshore Pipeline Regulations | All pipelines | Sec. 50 | For abandoned facilities left in place, disconnect from operating facilities, fill with approved medium, seal ends, empty storage tanks then purge of hazardous vapours, and maintain cathodic protection.[2] | ||
YUKON | National Energy Board | Canada Oil and Gas Operations Act (COGOA) | All pipelines | none specified | none specified |
N.W.T. | National Energy Board | Canada Oil and Gas Operations Act (COGOA) | All pipelines | none specified | none specified |
BRITISH COLUMBIA | Employment and Investment (Energy and Minerals Division) | Pipeline Act | All pipelines | Part II, Sec. 9 | Approval of Minister. Removal of structures which may be likely to menace public safety or create a fire hazard |
[1] This table lists current regulatory requirements
for pipeline abandonment only and does not address the abandonment of stations or
other above-ground facilities. Similarly, it does not address the requirements for
pipeline deactivation or discontinuance. [2] The NEB is in the process of amending its Onshore Pipeline Regulations and has proposed that these specific requirements be revoked, on the basis that abandonment applications will be treated on a case-by-case basis pending the outcome of the industry/government review into the matter. |
JURISDICTION | AGENCY | LAW | SCOPE | ABANDONMENT/ REMOVAL CLAUSE | ACTION REQUIRED |
---|---|---|---|---|---|
ALBERTA | Alberta Energy and Utilities Board | Pipeline Act | All pipelines | Part IV, Sec. 33 | Consent of the Board |
Pipeline Regulations | All pipelines | Secs. 66-69 | For facilities abandoned in place, disconnect abandoned pipeline from operating facilities, clean and purge with approved medium, cap all open ends and advise the Board when work is complete.[3] | ||
Alberta Environmental Protection | Environmental Protection and Enhancement Act (Alta. Reg. 115/93) | All pipelines on private land & Green Area | Sec. 122 | Reclamation Certificate from AEP | |
Alberta Agriculture, Food & Rural Development | Environmental Protection and Enhancement Act (Alta. Reg. 115/93) | Class I & II lines on White Area public lands | Reclamation Certificate from AFRD (responsibility delegated under EPEA) | ||
SASKATCHEWAN | Department of Energy and Mines | Pipelines Act | All pipelines | none specified | none specified |
MANITOBA | Oil and Gas Conservation Board | The Oil and Gas Act | All pipelines | Part 14, Sec. 171 | Application to an inspector. Responsible for any repairs required within six years from the day of issuance of the Certificate of Abandonment in respect of the oil and gas facility site. |
ONTARIO | Ministry of Consumer and Commercial Relations[4] | The Energy Act | All pipelines | none specified | none specified |
Gas Pipeline Systems Regulations | Gas pipelines | none specified | none specified | ||
Oil Pipeline Systems Regulations | Oil pipelines | none specified | none specified | ||
[3] Presently the EUB does not require the
removal of an abandoned pipeline; however, in most cases it will expect a notification
to the landowners, occupants, and those affected by sour gas setback distances of
the abandonment. This is to ensure that affected parties are made aware of the abandonment and that their land will no longer be impacted by the pipeline. [4]Starting in May 1997, Ontario's pipeline safety regulation program will be administered by the Technical Standards and Safety Authority, a private non-profit organization. |
JURISDICTION/ | AGENCY | LAW | SCOPE | ABANDONMENT/ REMOVAL CLAUSE | ACTION REQUIRED |
---|---|---|---|---|---|
QUEBEC | Regie du Gaz Naturel | Gas Distribution Act | Gas pipelines | none specified | none specified |
Regulations Respecting Gas and Public Safety | Gas pipelines | none specified | none specified[5] | ||
NOVA SCOTIA | Energy and Mineral Resources Conservation Board | Pipeline Act | All pipelines | Sec. 20 | Consent of the NSEMRCB |
NEW BRUNSWICK | Natural Resources and Energy | Pipeline Act | All pipelines | none specified | none specified[6] |
Pipeline Regulations | All pipelines | Sec. 85 | Consent of Minister and approval of Board. For facilities abandoned in place, disconnect abandoned pipeline from operating facilities, purge with approved medium, cap open ends and advise Minister when work is complete.[7] |
||
PRINCE EDWARD ISLAND | Department of Energy and Forestry | No applicable legislation | N/A | N/A | N/A |
NEWFOUNDLAND | Canada- Newfoundland Offshore Petroleum Board |
The Petrole um and Natural Gas Act |
Offshore pipelines[8] | none specified | none specified |
[5] Sec. 3(2) of the Regulations
Respecting Gas and Public Safety states that the construction, installation,
repair, maintenance, replacement or removal of any gas distribution piping shall be
in accordance with Code CAN1-B149.1-78 "Installation Code for Natural Gas Burning
Appliances and Equipment". [6]Sec. 28 of the Pipeline Act states that no pipeline shall be taken up or removed without consent of the Minister and subject to his conditions. [7]Secs. 83-84 of the Pipeline Regulations list the application requirements and criteria for the take up and removal of a pipeline, namely that it must be physically isolated from operating facilities, purged with an approved medium, and that the Board must be advised when the work is complete. [8]Newfoundland does not at present have any legislation applicable to onshore pipelines. |
Appendix B - Abandonment Checklist
1.0 | Alternate Use Analysis
|
2.0 | Product Removal & Cleaning 2.1 Liquids Pipeline
2.2 Gas Pipeline
|
3.0 | Information Required for Planning/Approvals 3.1 Facility Description/History
3.2 Regulatory Jurisdictions/Approvals
3.3 Landowner/Public Contact Activities
3.4 Environmental Assessment
|
4.0 | Identify Abandonment Activities (Develop Abandonment Plan)
4.1 Appurtenances Removal/Modifications
4.2 Crossings
4.3 Environmental Protection/Reclamation Activities
4.4 Pipe Removal
4.5 Salvage Analysis
4.6 Pipe Abandoned In Place
|
5.0 | Monitoring/Maintenance Activities
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Appendix C - Industry Questionnaire
ABANDONMENT INFORMATION
Refer to the following two pages for a copy of the abandonment questionnaire that was used for the industry survey conducted in autumn 1995.
Background Information
Owner/Operator: ________________________________________________________
Name of Pipeline: __________________________ Construction date: ______________
Location (Legal Description) From: ____________________ To: ___________________
Length: _______ Outside Diameter: _______ Wall Thickness: _______ Grade: _______
Substance(s) transported : ________________________________________________
Coating Type: External: _____________________ Internal: ______________________
Cathodic protection during operation: Impressed Current: ________ Anodes : ________
Depth of Pipe Burial: _____________________________________________________
Was the pipeline constructed through wet areas: Yes: _____ No: _____
Are you aware of any adverse soil conditions (i.e. salinic, acidic): Yes: _____ No: _____
If Yes, What Types:
______________________________________________________________________
Did the pipeline have any crossings (i.e. road, railway, water): Yes: _____ No: _____
If Yes, What Types:
______________________________________________________________________
Abandonment
Abandonment date: ______________________________________________________
Reason(s) for Abandonment: _______________________________________________
Pipe Condition at Abandonment:
External Corrosion: None _____ Some _____ Significant _____
Internal Corrosion: None _____ Some _____ Significant _____
Abandonment Activity:
When answering the items below, please note whether the answer refers to the entire pipeline or to specific parts of the pipeline.
Cleaning Procedure: __________________________________________________
Cleanliness Criteria: __________________________________________________
Capping (Weld Caps): Yes: _____ No: _____
If Yes: Frequency: ___________________________________________________
Number of Pipe Segments: _____________________________________________
Filling (i.e. N2, Concrete, Grout, etc.): Yes: _____ No: _____
If Yes: Fill Type: _____________________________________________________
Road/Railway Crossings: Yes: _____ No: _____
If Yes: How was Pipe Abandoned: _______________________________________
Water Crossings: Yes: _____ No: _____
If Yes: How was Pipe Abandoned: _______________________________________
Slopes: Yes: _____ No: _____
If Yes: How was Pipe Abandoned: _______________________________________
Plugging: Yes: _____ No: _____
If Yes: How was Pipe Abandoned: _______________________________________
Cathodic Protection: Retained: _____ Not Retained: _____
Monitoring After Abandonment
Type of monitoring: ______________________________________________________
Frequency of Monitoring: __________________________________________________
Summary of Monitoring Findings: ____________________________________________
______________________________________________________________________
Has an abandonment study ever been done on the pipeline to determine the effectiveness of the abandonment?
__________________________________________
______________________________________________________________________
Are alignment sheets and drawings available to help identify potential dig sites?
Yes: _____ No: _____
Since abandonment, are you aware of any:
a) Surface settlement over the pipe? Yes: _____ No: _____
If Yes, please provide details: __________________________________________
b) Water flow through the pipe? Yes: _____ No: _____
If Yes, please provide details: __________________________________________
c) Pipe exposure? Yes: _____ No: _____
If Yes, please provide details: __________________________________________
d) Environmental contamination? Yes: _____ No: _____
If Yes, please provide details: __________________________________________
e) Any other problems? Yes: _____ No: _____
If Yes, please provide details: __________________________________________
Have any additional abandonment measures been completed since the initial abandonment? Yes: _____ No: _____
If Yes, please provide details: ______________________________________________
______________________________________________________________________
Other Comments: _______________________________________________________
______________________________________________________________________
______________________________________________________________________
______________________________________________________________________
Is your company planning any type of excavation on or near this abandoned pipeline this summer? Yes: _____ No: _____
If Yes, please provide details: ______________________________________________
______________________________________________________________________
For further information contact :
Name: ____________________________________________________________
Title: _____________________________________________________________
Tel.: ______________________________ Fax: ___________________________
Appendix D - Cleaning Guidelines
D.1 General Considerations
The operating history of the pipeline to be abandoned should be reviewed to enable the planning of the specific cleaning procedures required for abandonment. Information such as oil/gas analysis, piping modifications, operating flow records, records of anomalies, and maintenance records may provide some insight into additional work needed to develop an effective pipeline cleaning plan.
The owner/operator should ensure that there are adequate sending and receiving traps in place. This may require the use of temporary assemblies. If the pipeline in question is part of a larger system, the section to be abandoned should be physically disconnected upon completion of the cleaning process.
Safety precautions appropriate to the in-service product hazards (i.e. flammability and explosivity of hydrocarbons, toxicity of sour products) must be established throughout the activity.
For gas pipelines, any residual gas should be vented or flared once the pressure in the pipeline has been reduced to the extent possible using operating facilities or a pull down compressor. The residual gas should be monitored for signs of liquid.
For liquid pipelines, before line flow ceases, a sufficient number of scraper pigs should be run through the line to remove the bulk of any solids or waxy build-up. As illustrated by the figure below, a batch of solvent-type hydrocarbons such as diesel fuel or condensate inserted between two scraper pigs is recommended as an effective method of reducing solids or waxy build-up. This process should be repeated until solids can no longer be detected on the pigs as they are removed from the receiving trap.
Figure D-1
In-Service Initial Cleaning for Liquid Pipelines
Specialized chemical cleaning may be required if the routine cleaning method described is not successful, if the pipeline is known to have an unusually high contamination level, or if unusually high cleanliness standards are to be met. Special precautions must be exercised when the pipeline is opened up to control vapour hazards of flammability, explosiveness, and toxicity (e.g. hazardous compounds such as benzene).
D.2 Cleaning Methods for Natural Gas Pipelines
A stiff rubber scraping pig should be pushed through the pipeline (at a constant speed consistent with the pig manufacturer's recommendation) using nitrogen or some other inert gas to prevent explosive mixtures. Free liquids pushed ahead of the pig may be either pushed into the downstream pipeline section or collected in a containment tank designed and isolated according to prevailing local guidelines, for disposal in accordance with area legislation or local by-laws. This process should be repeated until free liquids are no longer evident by visual inspection. Low areas of the pipeline should be checked for the collection of liquids or other contaminants.
After these initial pigging runs, the pipeline should be checked for cleanliness. If contamination is evident, the pigging procedure should be repeated using a slug of solvent between two pigs. As with the free liquids, the solvent should be collected in a containment tank and disposed of in accordance with area legislation or local by-laws. Solvent fumes should be purged with nitrogen or a similar inert gas.
D.3 Cleaning Methods for Liquid Pipelines
Following completion of the initial in-service cleaning efforts, a final cleaning step should be done in conjunction with line evacuation. The following procedure is commonly used, although many variations exist which should be considered. Consultants specializing in the cleaning of contaminated facilities can advise and provide plans for both normal and unusual circumstances.
A slug of liquid hydrocarbons having solvent properties such as condensate or diesel fuel is pushed through the pipeline between two stiff rubber scraper pigs at a constant speed by an inert gas such as nitrogen. Other additives or treatment chemicals may be added if desired. As a rule of thumb, the volume should be calculated to maintain a minimum pipe wall contact time by the fluid ranging from five to ten minutes (or longer), depending on the effectiveness of the initial in-service cleaning process.
For lines having encrusted or high paraffin build-up, an additional volume of solvent preceding the first pig can be considered. All contact times should be increased for excessive lengths of line as the solvent may become saturated with hydrocarbons before completion of the run. The following diagram illustrates the pipeline sequence of movement. At the endpoint, the solvent and hydrocarbons are pushed into another section of pipeline or collected in a containment tank for disposal.
Figure D-2 - Final Cleaning and Evaluation for Liquid Pipelines
A repeat run of the pig train described above should be conducted if there are any indications of liquids or contaminants remaining on the pipe wall in excess of the established cleanliness criteria. The effectiveness of the cleaning process can be gauged by either obtaining samples of the solvent near the tail end of the passing batch, at approximate 25 km intervals, and analyzing the samples for hydrocarbon content, or by monitoring the quality and quantity of the solvent hydrocarbons expelled from the line and comparing it with that injected.
Appendix E - Bibliography
The documents that were used in the preparation of this discussion paper are listed below. Copies of the studies that were commissioned by the Pipeline Abandonment Steering Committee are available from the Canadian Association of Petroleum Producers, the Canadian Energy Pipeline Association, the Alberta Energy and Utilities Board, and the National Energy Board.
Studies Commissioned by the Pipeline Abandonment Steering Committee
1. Roberts Thorne, Wendy E., Basso, Anne C., Sukhvinder, K. Dhol, Identification and Assessment of Trace Contaminants Associated with Oil and Gas Pipelines Abandoned in Place, Topical Report, Biophilia Inc., 1996.
2. Webster, R.D., Pipeline Corrosion Evaluation, Topical Report, Corrpro Canada, Inc., 1995.
3. Saunders, R., Preliminary Geotechnical Assessment of Pipeline Subsidence Phenomena, Topical Report, Geo-Engineering Ltd., 1995.
4. H.R. Heffler Consulting Ltd., and Tera Environmental Consultants (Alta.) Ltd., Environmental Issues Concerning Pipeline Abandonment, Topical Report, 1995.
Correspondence with Abandonment Committees
5. Letter dated 29 January 1995 from Montreal Pipe Line Limited with attached case history for 323.9 mm diameter pipeline abandoned in 1984.
6. Letter dated 2 November 1995 from Trans-Northern Pipelines Inc. outlining case history for a 219.1 mm diameter pipeline, referred to as the Ottawa Lateral, abandoned in segments between 1968 and 1987.
Other Papers
7. National Energy Board, Background Paper on Negative Salvage Value, September 1985.
8. Willatt, R.M., Abandonment of the Angle Bay-Llandarcy Cross Country Pipeline, Pipeline Industry Guild et al Pipeline Management 90 Symposium ' Proceedings, Paper No. 16, London, England, 13-14 June 1990.
9. Cooper, M.W., The Abandonment of Offshore Pipelines, Pipelines International, v 35, no 4, pp. 15-20, July-August 1990.
10. Starsmore, R.P., History of a Wet Gas Transportation Pipeline from Design through to Decommissioning, Pipelines International, v 35, no 4, pp. 11-14, July-August 1990.
11. O'Donoghue, A., Characteristics and Performance of Conventional Cleaning Pigs, Pipelines International, v 38, no 5, pp. 17-21, September-October 1993.
12. Anderson, S., Environmental and Safety Implications, IBC Technical Services Ltd. Decommissioning & Removal of Offshore Structures Conference Proceedings, London, England, 15-16 September 1993.
13. Keys, M. S., Evans, R., Gel Pig Technology Used In Pipeline Conversion, Pipeline Gas Journal, v 220, no 3, pp. 26-28,30,33, March 1993.
14. Linz, D.G., Woodyard, J.P., Geer, E. C., New Understandings in Prediction and Control of PCB (Polychlorinated Biphenyl) Migration in Gas Pipelines, Industrial Gas Technology Hazardous & Environmentally Sensitive Waste Management in the Gas Industry Conference Proceedings, Albuquerque, New Mexico, 20-22 January 1993.
15. Walsh, F.J., PCB Contaminated Gas Pipeline Risk Assessment, Topical Report, Roy F. Weston Inc., 1993.
16. Robinson, G., PCB (Polychlorinated Biphenyl) Site Investigation Adopts Efficient Sampling Strategy, Pipe Line Industry, v 75, no 2, pp. 51-55, February 1992.
17. Liebs, L. H., PCBs (Polychlorinated Biphenyl) in the Natural Gas Industry, Industrial Gas Technology Hazardous & Environmentally Sensitive Waste Management in the Gas Industry Conference Proceedings, Albuquerque, New Mexico, 20-22 January 1993.
18. Merilainen, K.J. (NOWSCO Well Service Inc), Pipeline Line Filling Abandonment Technologies, 16 August 1995.
19. van Everdingen, R. O., Potential Interactions Between Pipelines and Terrain in a Northern Environment, Technical Bulletin - Canada, Inland Waters Directorate, no. 114, 1979.
20. McNulty, J.G., Short, G.C., Russell, D.A., Predicting the Performance of Conventional Pigs, 4th Pipe Line Industry & Pipelines International Pipeline Pigging & Inspection Technology International Conference Proceedings, Paper No. 3, Houston, Texas, 17-20 February 1992.
21. Lewis, David L., Bishop, Mary K., Statistical Analysis of PCB Data from Natural Gas Pipelines, Radian Corporation Topical Report, 1991.
22. LaShier, R., The TSCA PCB Regulations and Their Effect on Pipeline Removal and Abandonment Programs, American Gas Association 1989 Operating Section Proceedings, Report No. CONF-8905185--, Technical Paper 89-DT-61, American Gas Association, Arlington, Virginia, 1989.
23. Norman, S., Fiscal Issues of Abandonment, IBC Technical Services Ltd. Decommissioning & Removal of Offshore Structures Conference Proceedings, London, England, 15-16 September 1993.
24. Metcalf, R., The Legal Requirements For Abandonment, IBC Technical Services Ltd. Decommissioning & Removal of Offshore Structures Conference Proceedings, London, England, 15-16 September 1993.
25. Fjelsa, O., Decommissioning and Removal in Norway, IBC Technical Services Ltd. Decommissioning & Removal of Offshore Structures Conference Proceedings, London, England, 15-16 September 1993.
26. Joy, M.F., Major Federal Legislative Initiatives Affecting the Industry, API Pipeline Conference Proceedings, Houston, Texas, 7-8 April 1992.
27. Sharp, W.R., Offshore Pipeline Abandonment, Gas Engineering and Management, vol 30, no 1, January 1990.
28. Huntington, A.A., A Practical Look at UK Pipeline Abandonment Legislation, Pipelines International & Aberdeen University - Pipelines & the Environment Conference Proceedings, Bournemouth, England, 8-10 March 1988.
29. Butler, W.C.F., UK Abandonment Policy: Development and Implementation, ASS Offshore Diving Contract et al Offshore Abandonment & Removal International Conference Proceedings (OAR '90), Aberdeen, Scotland, 27-29 March 1990.
30. U.K. Department of Trade and Industry, Abandonment of Offshore Installations and Pipelines under the Petroleum Act 1987: Guidance Notes for Industry (Consultative Document), 4 May 1995.
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