Bangor International Airport — Pipeline Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration SEP 2 8 Z015 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Anthony P. Caruso Jr., C.M. Airport Director Bangor International Airport 73 Harlow Street Bangor, Maine 0440 I Dear Mr. Caruso: In response to the City of Bangor request of August 17, 2012, by letter dated February 18, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA) provided the City of Bangor with information concerning the regulatory status of a hazardous liquid pipeline that transports jet fuel from a tank facility to the fuel hydrant system at the Bangor International Airport. The February 18, 2014, letter advised the City of Bangor that the exemption in 49 CFR 195.1 (b )(3)(ii) for certain low stress pipelines that serve terminal facilities does not apply to the pipeline. In a subsequent letter to PHMSA dated March 25, 2015, you stated that the city is evaluating options to alter its pipeline from a pressurized system to a gravity type system. The city would relocate the pumps downstream to a location inside the airport's fence line. The resulting relocation would, by your evaluation, create a low-stress gravity feed system. In addition, in a May 7, 2015, letter you responded to questions asked by Mr. Steve Nanney of PHMSA's engineering staff. One of your responses provided PHMSA with an elevation profile of the pipeline. The elevation profile shows the lowest elevation point to be in the middle of the pipeline. Also, flow into the pipeline from the storage tank would involve the assistance of a remote suction pump. Based on the information you provided on the elevation profile and the use of a suction pump, the pipeline would not be considered a gravity pipeline. If we can be of further assistance, please contact Tewabe Asebc of my staff at 202-366-5523. ;i;# \.......---/'.. John A. Gale / Director, Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 2APR 0 1 2015 March 25, 20 15 Mr. John Gale Director, Standards and Rulemaking Pipeline and Hazardous Materials Safety Administration (PHMSA) Department of Transportation (DOT) 1200 New Jersey Avenue SE Washington, DC 20590 Re: Bangor lnh ~ rn ati onal Airport Fuel Pipeline - exemption from DOT regulations request. Dear Mr. Gale: The City of Bangor owns and operates the Bangor International Airport (BGR). As part of the operation on the airport, BG R uses a fuel pipeline to transfer jet fuel from storage tanks, located outside of the airfield, to a hydrant system on the airfield. Less than one (I) mile of this pipeline fall s on land located outside of the airfield and accessible to the general public . After a significant period of investigation and discussion, the Eastern Regional office of PHMSA has determined that' the pipeline falls under DOT jurisdicrion. However, after further discussions with DOT officials and the City's contracted pipeline specialist, it was recommended that the City may wish to request an exemption ruling from you on this subject.· As we understand, 49- C.F.R. # 195 {b) lists a number of exceptions regarding DOT jurisdiction of pipelines. These exceptions apply to pipelines that are: 1) Are low-stress. 2) Serve refining, manufacturing, or truck, rail, or vessel terminal faci lities: 3) Are less than one mile long (measured outside facility grounds). 4) Do not cross an offshore area or a waterway currently used for commercial navigation ( 195{b) (3) (i i). Following the exemptions listed above, the City is eva luating options to alter our fuel pipeline from a pressurized system to a gravity type system. We would relocate the pumps to a location inside the airport's fence lin( c:nd hcnc.c eliminate the crossing of roa.:h v~ys ;,nd other publi:; .;jJ:lC·:'.i. The transpc,rtatio;: -:: fa hazardous liquid wiH be through this system. The result would create a low-stress, gravity feed system. An additional exemption the City is reviewing is stated in section # 195 .2(9), transportation of a hazardous liquid or carbon dioxide: (i) by vessel, aircraft, tank truck, tank car, or other non-pipeline mode of transportation; or (ii') through facilities located on the grounds of a materials transportation terminal if the faci lities are used exclusively to transfer hazardous liquid or carbon dioxide between non-pipeline modes of transportation or between a non-pipeline mode and a pipeline. Our facility does not include any device and associated piping that are necessary to control pressure in the pipeline under # 195.406(b). Our system transfers fuel to tank trucks and hydrant trucks: These hydrant trucks are the same design and · specifications utilized by the United States Air Force. As determined by the Government, their system· utilizes, · and is deemed a "truGk". Please see attached document. . . ... In addition, as mentioned above, less·than one (I) mile ofth"e length ofthe-fuel 'pipeline is located outside of the airJ)ort fence line .. The pipeline does not cross an offshore area or a waterway that is used for commercial navigation. 287 Godfrey BouJe,·ard, Bangor, ME O.J.JOI USA Tel: 207.LJ<J2..J6(10 F.1': 207.9-1:>.:16117 \1"\1"1\".lh·b,mg<•r.n>rn#

Page 3The City of Bangor is respectfully requesting your review and ruling of the request for an exemption from DOT regulations as defined by the above criteria. Please fee l free to contact me should you have any questions or concerns. We appreciate your review and guidance on this matter. Very Kind Re~, '7) _ \ / lft 4~? Anthony P. Caruso Jr., C.M. Airport Director Bangor International Airport Attachment: Fuel Truck Technical specification designation. CC: Byron Coy P.E., Director Karen Gentile, Community Assistance & Technical Services (CATS) Manager John Theriault, City of Bangor Engineer Wynne Guglielmo, Environmental Coordinator Robbie Beaton, Superintendent of Airport Operations Gil Merchant, Fuel Farm Supervisor#

Page 4l'-1\1{''\\1'10'-\l \IIU'IlH 1 May 7, 2015 Mr. Steve Nanney, PHSMA PHMSA Pipeline Safety Southwest Region Office 8701 S. Gessner Road, Suite 1110 Houston, TX 77074 Re: Bangor International Airport - 12-inch Diameter Jet Fuel Pipeline - Interpretation Letter (2) Dear Mr. Nanny, The Bangor International Airport (BGR) is pleased to respond to the questions you posed in your email of May 4, 2015 concerning our underground jet fuel pipeline. Please see below and the attached diagram for items which address these questions and concerns. DOT Questions & Resoonses: 1. What is the 12-inch pipeline proposed maximum operating pressure (MOP) in psig? Note: various MOPs were in email. a. The MOP for the system is set at 150 PSI. Our fuel system is designed to shut down automatically if the pressure exceeds 150 PSI. The normal operating pressure is 85 PSI. 2. What was the maximum and minimum pressure of the 8-hour pressure test? a. During the DOT hydro test, the starting pressure was 164 PSI. In the first four (4) hours of the test, the pressure increased to 175 PSI, due to thermal expansion. Following the next four (4) hours we reduced the pressure to 124 PSI, and it only reached a max pressure of 139 PSI, thus confirming a tight pipeline. Max pressure = 175 psi, Min pressure = 124 psi. 3. How man tests/ inspections were conducted on the pipeline to determine the pipe wall thickness, grade, and seam type? Where were they taken? a. BGR performed two tests of the pipe thickness as documented. When we replaced a valve at lateral # 1, the pipeline was measured for thickness and the seam was checked. We also had the pipe tested when we repaired the low point drains at lateral tt2 and #3. The 12" pipe that was removed was sent to our contractor and pipe was measured for thickness and seam checked. 4. Do you have any other information on the pipe properties? a. No additional documentation has been discovered. However, we do have blueprints of the pipeline from 1956, but they do not contain and pipe specifications. 5. Will the pump be located at the end of the pipeline just prior to the pipeline tying into the tank near the airport ramp?#

Page 5a. We plan to locate the pump inside the fence line on the 10" pipeline that is connected to the 12" pipeline in lateral #5. The pump will be located on the inlet piping, downstream of the filter vessels, behind the containment building. 6. What is the elevation difference between the starting and endings points of the pipeline? a. The low points of the fuel system are at laterals #3 and #4. Both ends of the line are slightly higher than those points. This is where we drain the line to empty the line for maintenance. b. Elevations are provided on the attached diagram. 7. Do you have an elevation profile along the pipeline route? a. Elevations are provided on the attached diagram. Please review the enclosed material and let me know if you have any questions or need any additional information for your determination for exemption status. Thank you for your consideration of this matter. - ~ Anthony P. Caruso Jr., C.M. Airport Director Bangor International Airport • AttachmentS: Bangor International Airport - Proposed Pump Station aerial diagram . CC: John Gale, Director, Standards & Rule Making Byron Coy P.E., Director Kay Mciver, PHSMA Karen Gentile, Community Assistance & Technical S ervices (CATS) Manager John Theriault, City of Bangor Engineer Wynne Guglielmo, City of Bangor Environmental Coordinator Robbie Beaton, Superintendent of Airport Operations Gil Merchant, Fuel Farm Supervisor#

Page 6BANGOR INTERNATIONAL AIRPORT Jet Fuel Pipeline (including Lateral Control Pits) and Proposed Pump Station 1" = 400' @ 8.5x11 April 2015 by scg Feet 0 125 250 500 750 1,000#

Page 7BANGOR INTERNATIONAL AIRPORT Jet Fuel Pipeline Elevations (estimated) 1"=400' @ 8.5x1 1 May 2015 by scg Feet 0 125 250 500 750 1,000#