{"operation":"document","citation":"PI-01-0103","title":"Marathon Ashland Pipe Line, LLC — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-02-15","effective_on":null,"summary":"PI-01-0103 response to Marathon Ashland Pipe Line, LLC concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-02-15_Schell_195.1-wmx.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0103\nFebruary 15, 2001\nMr. Tad A. Schell\nRegulatory Compliance Officer\nMarathon Ashland Pipe Line, LLC\n539 South Main Street\nFindlay, OH 45840-3295\nDear Mr. Schell:\nI am responding to your letter concerning an LPG storage tank on the grounds of a refinery. You requested our\nopinion on whether the tank is subject to 49 CFR Part 195.\nAccording to your letter, the refinery produces LPG from crude oil and stores it in the tank for use at the refinery\nor sale to marketers. The refinery also transfers LPG back and forth between the tank and a remote storage\ncavern via regulated pipelines.\nAs provided in § 195.1(b)(7), Part 195 does not apply to \"transportation of a hazardous liquid or carbon dioxide\nthrough onshore production (including flow lines), refining, or manufacturing facilities, or storage or in-plant\npiping systems associated with such facilities.\" Thus, storage associated with refining facilities is not covered by\nPart 195. It follows that because the LPG tank in question is associated with refining operations, Part 195 does\nnot apply to the tank.\nI hope this information meets your needs. If you would like further assistance, please call Mr. Lucian Furrow, of\nmy staff, at (202) 366-4559.\nSincerely,\nRichard D. Huriaux, P.E.\nRegulations Manager\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nMarathon Ashland Pipe Line, LLC\n539 South Main Street\nFindlay, OH 45840-3295\nOctober 18, 2000\nMr. Richard D. Huriaux, P.E.\nDirector of Technology and Regulations\nOffice of Pipeline Safety, USDOT\n400 Seventh St. SW\nWashington, D.C. 20590-0001\nRE: Determination of refining equipment not being subject to Part 195 Dear Mr. Huriaux:\nMarathon Ashland Pipe Line Company has been working with it's Refinery clients to determine if certain\nequipment within a refinery perimeter connected to a pipeline is subject to 49 CFR part 195.\nBased on our understanding of Part 195, we have made a determination that Butane sphere at one of our\nrefining customer locations is not subject to 49 CFR part 195. We seek OPS concurrence of our determination.\nBackground\nA Petroleum refinery customer has a Butane Sphere (n-Butane) located on the southeast corner of the refining\nfacility. The Butane Sphere was constructed in 1976, in compliance with ASME codes in effect at the time of\nconstruction. The refinery itself was originally constructed in the 1930's with various additions in succeeding\nyears. The facility is located in a commercial and light industrial area near several other petroleum terminals,\ndistribution warehouses, and small businesses.\nThe primary business activity of the refining complex is the conversion of crude oil into petroleum products. In\nthe course of this conversion, LPG (chiefly Propane and Butane) products and intermediates are produced. These\nmaterials are either sold to marketers or used within the refining complex for gasoline blending to meet EPA\nmandated RVP targets. The volume of these LPG materials produced by the refinery is relatively constant,\nhowever the consumption varies seasonally. In the fall and winter months, the refinery requires more Butane for\ngasoline blending than is produced, and in the spring and summer, the refinery produces excess LPG.\nTo best utilize this material, an offsite LPG cavern facility, located approximately 14 miles away, is utilized to\nstore LPG materials in times of excess LPG production, and supply LPG to the refinery when the refinery requires\nadditional LPG. This cavern facility is connected to the refinery via two pipelines.\nPart 195 Applicability\nPart 195 requirements apply to 1) pipelines between the LPG cavern facility and 2) refinery, and Refinery LPG\nstation pipeline pressure safety devices and associated piping necessary to keep the pipeline from exceeding the\nMOP requirements of 49 CFR 195.406(b).\nMost of the piping at the refinery LPG terminal can be differentiated as part 195 or non-part 195 piping using the\nrules in part 195.1. Our implementation of part 195.1 at the Refinery LPG station is shown on the attached\ndrawing, Exhibit A.\nHowever, the direction of pipeline flow, as explained earlier, varies seasonally. Typically, from mid-May to mid-\nAugust, excess refinery LPG is shipped via pipeline from the refinery to the cavern facility; from mid-September\nto mid-April, LPG is shipped from the cavern facility to the refinery. As such, the Butane sphere is seasonally,\nswitched between a \"receive-from pipeline\" mode and a \"ship-to-pipeline mode.\"\nAs you can see, the tank is not truly a traditional pipeline breakout tank. A breakout tank provides either 1) an\nintermediate storage point between two pipeline segments, or 2) accepts surge (relief) pressure from a pipeline\n\n<<<PAGE 3>>>\n\nsystem. Sometimes, the Butane sphere receives material in from the LPG pipeline system (please see Exhibit B)\nand at other times the Butane sphere provides material for shipment out through the same pipeline (please see\nExhibit C). In other words, the tank is a terminal tank. Sometimes the terminal is receiving, and sometimes the\nterminal is shipping, but always through the same pipeline. This Butane Sphere does not serve as pressure relief\nsurge vessel to the LPG pipeline system.\nOther Information\nIn addition to serving as a pipeline terminal tank, the Butane sphere is intimately involved with refinery\noperations. The vessel receives process unit run-down from several units, such as the alkylation unit de-\nisobutanizer tower, and the MTBE unit debutanizer. The Butane sphere also supplies feedstock to the gasoline\nblending unit.\nThe Butane sphere is subject to the OSHA PSM standard, which is equivalent to part 195 vessel maintenance and\nintegrity practices (i.e. API 2510 is followed). In addition, the Butane sphere is currently maintained by refinery\npersonnel who are trained and qualified in refinery operation and maintenance procedures.\nConclusion\nBased on the above, we believe the sphere is not subject to 49 CFR Part 195. Please contact me if you require\nfurther information to consider this matter.\nSincerely,\nTad A. Schell, P.E.","truncated":false,"body_characters":6069}