{"operation":"document","citation":"PI-04-0107","title":"BP America Production Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-04-20","effective_on":null,"summary":"PI-04-0107 response to BP America Production Company concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0107.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0107.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0107","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2004/g04-04-20_Williamson_195.1-wmx.pdf","body":"<<<PAGE 1>>>\n\nPI-04-0107\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\nApril 20, 2004\nMr. George Williamson\nOnshore United States Business Unit\nDOT Regulatory Compliance Manager\nBP America Production Company\n501 Westlake Park Blvd.\nOffice 2.366\nHouston, TX 77079\nDear Mr. Williamson:\nThis is in response to your letter of March 31, 2004, in which you request an interpretation of the gas pipeline\nsafety regulations at 49 CFR 195.1, Applicability. You ask whether a 2 to 3.5 inch diameter pipeline transporting\npetroleum from a production facility to a refinery in a rural area is a gathering line that is excepted by § 195.1(b)(4) from\ncompliance with the pipeline safety regulations of Part 195.\nSection 195.1(b)(4) specifies that Part 195 does not apply to \"transportation of petroleum in onshore gathering\nlines in rural areas . . .\" Gathering line is defined in § 195.2 as a pipeline less than 8 5/8 inches outside diameter that\ntransports petroleum from a production facility. The same section defines Production facility as piping used in the\nproduction, extraction, recovery, lifting, stabilization, separation, or treating of petroleum.\nBased on your representation that the pipeline in a rural area near Evanston, Wyoming, is less than 8 5/8 inches\noutside diameter and transports petroleum directly from a production facility, it appears that the pipeline meets the\nrequirements of § 195.1(b)(4). Therefore, it is not subject to safety regulation under Part 195.\nHowever, a final determination of the regulatory status of your pipeline can only be made pursuant to\ninspection by the Office of Pipeline Safety. If you have questions about inspection procedures, please contact the Office\nof Pipeline Safety's Western Region office in Lakewood, CO at 303-231-5701.\nIf you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nGeorge Williamson\nOnshore united States Business Unit\nDOT Regulatory Compliance Manager\nBP American Production Company\n501 Westlake Park Blvd\nHouston, TX 77079\nMarch 31, 2004\nOffice of Pipeline Safety (DPS-10)\nResearch and Special Programs Administration\nU. S. Department of Transportation\n400 Seventh Street, SW.\nWashington, DC 20590-0001\nRe: Request for Interpretation\nDear Sir or Madam:\nWe are requesting a written interpretation on the applicability of 49 CFR Part 195 regulations to our Painter Production\nfacility condensate pipeline. We have reviewed the scope of the regulations and concluded that the condensate pipeline\nmeets the requirements of exception criterion §195.1(b)(4). We would like to share our methodology and ask that you\nverify that our pipeline is not subject to the regulations in 49 CFR Part 195.\nThe pipeline in question transports condensate from our Painter Production Facility to the Silver Eagle Refinery near\nEvanston, Wyoming. The primary function of the Painter Production Facility is to separate and stabilize gas and\npetroleum liquids from our production wells. The pipeline is located entirely in onshore rural areas (total length\napproximately 8 miles). The pipeline diameter varies from 2 inches up to a maximum of 3.5 inches.\nOur conclusion is based on the exemption for petroleum gathering pipelines in\n§195.1(b)(4) and application of three key definitions from §195.2. Section §195.1(b)(4) specifies that the regulations do\nnot apply to transportation of petroleum in onshore gathering pipelines in rural areas. The three key definitions in\n§195.2 are: gathering pipeline, petroleum, and production facility (reference below).\nGathering Pipeline means a pipeline 219.1 mm (8 5/8 in) or less nominal outside diameter that transports petroleum\nfrom a production facility.\nPetroleum means crude oil, condensate, natural gas, natural gas liquids, and liquefied petroleum gas.\nProduction Facility means piping or equipment used in the production, extraction, recovery, lifting, stabilization,\nseparation or treating of petroleum or carbon dioxide, or associated storage or measurement. If you require additional\ninformation or would like to discuss the issue, please call me at 281-366-7843. Otherwise, please respond to us in\nwriting at your earliest possible convenience.\nSincerely,\nGeorge C. Williamson\nDOT Regulatory Compliance Manager","truncated":false,"body_characters":4438}