{"operation":"document","citation":"PI-11-0005","title":"Sabco Oil and Gas Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-08-11","effective_on":null,"summary":"PI-11-0005 response to Sabco Oil and Gas Corporation concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2011/Sabco-PI-0005-08-11-2011-Parts%20192%20and%20195.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nAUG 1 1 2611\nMr. Max Jameson\nEnvironmental/Regulatory Manager\nSabco Oil and Gas Corporation\n34 S. Wynden Drive\nHouston, TX 77056\nDear Mr. Jameson:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nApril 6, 2011, you requested an interpretation to determine the applicability of the Federal\npipeline safety requirements as they relate to the filing of annual reports for your pipeline system.\nYou provided a map of your offshore gas pipeline system and identified the system to include\nflow lines from wellheads to two platforms, a 1 0-inch gas transmission line, a 4-inch emulsion\nline, a 3-inch condensate line, a 4-inch produced water line, and a 1 0-inch condensate line.\nYou described your system as a gas gathering operation that transports full-stream product\n(gas+ condensate+ produced water) in 2.5-inch flow lines from the wellheads to the two\nproduction platforms, where it is then separated. The produced water is either discharged or\ncarried in the 4-inch water line to an onshore disposal well. The separated gas is either sold to a\ncommercial gas transmission line at the platforms, or recombined with the separated condensate\nand carried to an onshore tank battery by a gathering pipeline. You stated that the pipeline\nsystem is only a few miles long and is within the offshore waters of the State of Texas.\nYour opinion of a gathering or transmission pipeline is the line that carries products from your\noffshore platforms to your onshore tank battery. You ask whether you should include the flow\nlines in the pipeline safety annual reporting requirements.\nPer 49 CFR 192.1 (b)(1) and 195.1 (b )(5), the offshore gathering of gas or crude oil in state waters\nupstream from the outlet flange of each facility where hydrocarbons are produced or where\nproduced hydrocarbons are first separated, dehydrated, or otherwise processed, whichever\nfacility is farther downstream, is not subject to the pipeline safety regulations in Parts 192 and\n195. Accordingly, the 2.5-inch flow lines are not regulated by PHMSA. The 1 0-inch gas line, as\nidentified by you, is regulated as an offshore transmission pipeline. Since separation first occurs\nat platform 62, the 4-inch emulsion line is a regulated offshore gas gathering line beginning at\nthe outlet of the separator on platform 62. Likewise, since separation first occurs for the 3-inch\ncondensate line at platform 62 and then the condensate is combined with additional product at\nplatform 49, this line is a regulated offshore hazardous liquid gathering line beginning at the\noutlet of the separator on platform 62. The 4-inch produced water line would be a production or\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application ofthe regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nflow line and is not regulated by PHMSA. Finally, the 1 0-inch condensate line that connects\nplatform 49 with the onshore tank battery is a regulated hazardous liquids transmission line.\nIt is important to note that the pipeline system is an intrastate pipeline system regulated by the\nState of Texas. Therefore, we recommend that you contact the Railroad Commission of Texas\n(the state's regulatory agency) for determination of any additional annual reporting requirements\nand applicable pipeline safety regulations within the state's regulatory authority.\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat 202-366-4046.\ncc: Texas Railroad Commission\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CPR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nAPR 1 8 2011\nVia Certified Mail No. 70012510000163028549\nReturn Receiot Reauested\nApril 6, 2011\nOfficial Request for Interpretation\nAttn: Mr. John Gale\nDirector of Regulations (PHP-30)\nUSDOT/PHMSA\n1200 New Jersey Avenue SE\nEast Bldg., Room E22-321\nWashington, DC 20590\nDear Mr. Gale:\nSabco Operating Company hereby requests official interpretation of PHMSA of USDOT in\nregards to jurisdictional status of flow-lines in an offshore production system. Sabco is an oil\nand gas production company that operates two offshore gas-gathering platforms and one oil\nplatform. In our gas gathering operation, full-stream product (gas + condensate + produced\nwater) is carried in 2.5\" flow lines from the wellheads to our production platforms. The full-\nstream product is separated on the platforms. The produced water is either discharged or\ncarried in a water line to an onshore disposal well. The separated gas is either sold to a\ncommercial gas transmission line at the platform, or it is recombined with the separated\ncondensate and is carried to an onshore tank battery via a gathering line. The attached\nschematic diagrams illustrate the flow of products in Sabco's gathering system.\nOur interpretation of a \"gathering/transmission\" line is the line that carries products from our\noffshore platforms to our onshore tank batteries. The gathering lines are only a few miles long\nand are all intrastate. How should we treat our flow lines as applied to our pipeline safety\nannual reports? Should we report them as part of our gathering system and calculate the total\nlength of all our flow lines to be added to our gathering/transmission line? Or should we only\nregard the lines between our production platforms and our onshore tank batteries as\n\"gathering/transmission\" lines? The line segments have been numbered on the schematic\ndiagrams. Please interpret the jurisdictional status of each line segment by number and specify\nwhether each line segment is part of our production system or a gathering/transmission line.\nSincerely yours,\nSabco Operating Company\nMax Jameson\n\n<<<PAGE 4>>>\n\n2008-06-01 EC Flow Diagram-simplified.xls\nSabco Encinal Channel Gas Gathering System in Corpus Christi Bay, Texas\n2\nPLTFM\n3\nPLTFM\n62\n4\n49\nGregory Onshore\nTank Battery\n5\nLegend\nDisposal\nwellheads\nwell\n1 B\nFlow Lines from wellheads\n2 B\n10\" Gas Tansmission line (Southcross Line)\n3 E\n4\" emulsion line (recombined gas, condensate, water)\n4 B\n3\" condensate line\n5 ₴\n4\" produced water line\n6 E\n10\" condensate line (Southcross Line)\n\n<<<PAGE 5>>>\n\n2008-06-01 EC Flow Diagram-simplified.xis\nPlatform 62 Flow Schematic\n(Gar Sales) Souncross: 10\" to PL49 (HP)\nChange od Custody\nLEGEND\nWellheads\n2.5\" Flow Lines (multiple)\nI A\n1\nFull well stream\nGas\nGas\nHP SEP\nCondensate\n1-\nWater\nWater\nREVISION DATE: 5-1-2008\n3\" line to PL49 (HP Oil)\n4\" water line to PL49\n→\nWellheads\n2.5\" Flow Lines (multiple)\n1\nGas\n4\" line to PL49 Prod Sep\n1\nA I\nLP SEP\nOil\nWater\nRecom bined Prochet\n\n<<<PAGE 6>>>\n\nPlatform 49 (PL49) Flow Schematic\nPlatform B\nSouthcross 16° GAS LINE TO GREGORY\nGas\nChange of custody\n2\nHP SEP\nOil\n• 0 • I\nWater\n- P4920\nLEGEND\nFull well stream/Emulsion\nGas\n• Condensate\nREVISION DATE: 5-1-2008\nwater\n4\" Water Line FROM PL62\nEXISTING 4\" H2O LINE TO GREGORY\n= 5\n3\" HP OIL Line FROM PL62\nSouthcross 10\" HP GAS Line FROM PLE2\nCrosstex 10\" OIL LINE TO GREGORY\n= 6=\n→\nPlatform A\n4\" line from PL62 (Recombined products)\nGas\nLP SEP\nOil\nWater\nP19H20\n\n<<<PAGE 7>>>\n\n2008-06-01 EC Flow Diagram-simplified.x/s\nGregory Tank Battery (GR) Flow Schematic\n4\" Water Line From PL49\nSabco Disposal\nWell\n10°01 Line From PLA\nSEP\nTank","truncated":false,"body_characters":8151}