{"operation":"document","citation":"PI-01-0112","title":"ExxonMobil Production Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-06-14","effective_on":null,"summary":"PI-01-0112 response to ExxonMobil Production Company concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0112.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0112.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0112","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-06-14_Brooks_192.1-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0112\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\nJune 14, 2001\nMr. T. S. Brooks\nExxon Mobil Production Company\nU.S. East\nP.O. Box 61707\nNew Orleans, LA 70161-1707\nDear Mr. Brooks:\nIn your letter of March 23, 2001, you requested an interpretation of safety jurisdiction for pipelines carrying\nnatural gas and petroleum-based hazardous liquids between production platforms located entirely on the Outer\nContinental Shelf (OCS) in the Gulf of Mexico. You noted that they are regulated by the Department of the Interior's\nMinerals Management Service (MMS) as production facilities. These pipelines are supplied from a shore-based facility\nto the first platform on the OCS through pipelines that are regulated by the Office of Pipeline Safety (OPS) under\nprovisions of 49 CFR Parts 192 and 195.\nWe agree that pipelines between production platforms on the OCS are exempt from the pipeline safety\njurisdiction of OPS. The pipeline safety regulations at 49 CFR §§ 192.2(b)(5) and 195.1(b)(6) exempt pipelines located\non the OCS upstream of the point where operating responsibility transfers from a producing operator to a\ntransporting operator.\nIf you need further assistance, please call me at (202) 366-4565.\nSincerely yours,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nExxonMobil Production Company\nU.S. East\nP.O. Box 61707\nNew Orleans, Louisiana 70161-1707\nMarch 23, 2001\nPipeline Jurisdiction Determinations\nGulf of Mexico, Mobile Area\nOffshore Alabama\nMr. Richard Huriaux\nDirector T&R (rm#2325,DPS-10)\nUS DOT - RSPA\n400 Seventh Street, SW\nWashington, DC 20590\nDear Mr. Huriaux,\nExxonMobil Production Company herein requests your opinion concerning the jurisdiction of pipelines\ntransporting natural gas and oil-based liquids to be used for corrosion inhibition that are located between\nplatforms entirely on the OCS. These pipelines are producer-operated, and would normally be regulated by the\nMMS, and not the DOT, according to the Direct Final Rule issued by the DOT on November 11, 1997 (62 FR\n61692). However, the natural gas and oil-based fluids that these pipelines transport are delivered to the OCS\nfrom a shore based facility through DOT-jurisdictional pipelines.\nAs shown on the attached schematic, the DOT-jurisdictional gas pipeline originates onshore at a gas treating\nfacility and transports \"sweet\" gas for fuel usage, and terminates at a platform on the OCS. From that point, this\nfuel gas is then transported in separate, individual pipelines to other nearby facilities. Likewise, the DOT\njurisdictional liquid pipeline originates at the onshore treating facility and terminates at the OCS platform. Then,\nthe liquids are transported via individual pipelines to nearby facilities located entirely on the OCS where it is used\nfor corrosion inhibition. It is our opinion that only the pipeline(s) that transport the natural gas / oil-based fluids\nfrom the shore to the first OCS platform are regulated by the DOT, and that any subsequent pipelines between\nOCS platforms downstream of that point are \"producer operated\" and are properly regulated by the MMS as OCS\npipelines. However, since neither the MMS's nor the DOT's rules were written with this specific situation in mind,\nwe ask for your concurrence with our interpretation.\nCurrently, the MMS pipeline records indicate that these pipelines are under the jurisdiction of the MMS.\nFurthermore, representatives with the DOT, Office of Pipeline Safety Atlanta Regional Office, have indicated that\nthey are basically in agreement with our interpretation. However, they have recommended that an official\ndetermination be made by your office. Please be advised that these pipelines are not regulated by the Federal\nEnergy Regulatory Commission (FERC).\nPlease contact Mr. Steve Ledet at (504) 561-4824 if you have any questions or require any additional information\nin this matter.\nSincerely,\nT.S. Brooks\nEXXON MOBIL CORPORATION","truncated":false,"body_characters":4035}