{"operation":"document","citation":"PI-15-0005","title":"Bangor International Airport — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-09-28","effective_on":null,"summary":"PI-15-0005 response to Bangor International Airport concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/City_of_Bangor2_PI_15_0005_09_28_2015_Part_195_0.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nSEP 2 8 Z015\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Anthony P. Caruso Jr., C.M.\nAirport Director\nBangor International Airport\n73 Harlow Street\nBangor, Maine 0440 I\nDear Mr. Caruso:\nIn response to the City of Bangor request of August 17, 2012, by letter dated February 18, 2014,\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) provided the City of\nBangor with information concerning the regulatory status of a hazardous liquid pipeline that\ntransports jet fuel from a tank facility to the fuel hydrant system at the Bangor International\nAirport. The February 18, 2014, letter advised the City of Bangor that the exemption in 49 CFR\n195.1 (b )(3)(ii) for certain low stress pipelines that serve terminal facilities does not apply to the\npipeline.\nIn a subsequent letter to PHMSA dated March 25, 2015, you stated that the city is evaluating\noptions to alter its pipeline from a pressurized system to a gravity type system. The city would\nrelocate the pumps downstream to a location inside the airport's fence line. The resulting\nrelocation would, by your evaluation, create a low-stress gravity feed system.\nIn addition, in a May 7, 2015, letter you responded to questions asked by Mr. Steve Nanney of\nPHMSA's engineering staff. One of your responses provided PHMSA with an elevation profile\nof the pipeline. The elevation profile shows the lowest elevation point to be in the middle of the\npipeline. Also, flow into the pipeline from the storage tank would involve the assistance of a\nremote suction pump. Based on the information you provided on the elevation profile and the\nuse of a suction pump, the pipeline would not be considered a gravity pipeline.\nIf we can be of further assistance, please contact Tewabe Asebc of my staff at 202-366-5523.\n;i;#\n\\.......---/'.. John A. Gale\n/ Director, Office of Standards\nand Rulemaking\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 of the 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\nAPR 0 1 2015\nMarch 25, 20 15\nMr. John Gale\nDirector, Standards and Rulemaking\nPipeline and Hazardous Materials Safety Administration (PHMSA)\nDepartment of Transportation (DOT)\n1200 New Jersey Avenue SE\nWashington, DC 20590\nRe: Bangor lnh ~ rn ati onal Airport Fuel Pipeline - exemption from DOT regulations request.\nDear Mr. Gale:\nThe City of Bangor owns and operates the Bangor International Airport (BGR). As part of the operation on\nthe airport, BG R uses a fuel pipeline to transfer jet fuel from storage tanks, located outside of the airfield,\nto a hydrant system on the airfield. Less than one (I) mile of this pipeline fall s on land located outside of\nthe airfield and accessible to the general public .\nAfter a significant period of investigation and discussion, the Eastern Regional office of PHMSA has\ndetermined that' the pipeline falls under DOT jurisdicrion. However, after further discussions with DOT\nofficials and the City's contracted pipeline specialist, it was recommended that the City may wish to\nrequest an exemption ruling from you on this subject.·\nAs we understand, 49- C.F.R. # 195 {b) lists a number of exceptions regarding DOT jurisdiction of pipelines.\nThese exceptions apply to pipelines that are:\n1) Are low-stress.\n2) Serve refining, manufacturing, or truck, rail, or vessel terminal faci lities:\n3) Are less than one mile long (measured outside facility grounds).\n4) Do not cross an offshore area or a waterway currently used for commercial navigation ( 195{b) (3) (i i).\nFollowing the exemptions listed above, the City is eva luating options to alter our fuel pipeline from a\npressurized system to a gravity type system. We would relocate the pumps to a location inside the airport's\nfence lin( c:nd hcnc.c eliminate the crossing of roa.:h v~ys ;,nd other publi:; .;jJ:lC·:'.i. The transpc,rtatio;: -:: fa\nhazardous liquid wiH be through this system. The result would create a low-stress, gravity feed system.\nAn additional exemption the City is reviewing is stated in section # 195 .2(9), transportation of a hazardous\nliquid or carbon dioxide: (i) by vessel, aircraft, tank truck, tank car, or other non-pipeline mode of\ntransportation; or (ii') through facilities located on the grounds of a materials transportation terminal if the\nfaci lities are used exclusively to transfer hazardous liquid or carbon dioxide between non-pipeline modes of\ntransportation or between a non-pipeline mode and a pipeline. Our facility does not include any device and\nassociated piping that are necessary to control pressure in the pipeline under # 195.406(b). Our system\ntransfers fuel to tank trucks and hydrant trucks: These hydrant trucks are the same design and ·\nspecifications utilized by the United States Air Force. As determined by the Government, their system·\nutilizes, · and is deemed a \"truGk\". Please see attached document.\n. . ...\nIn addition, as mentioned above, less·than one (I) mile ofth\"e length ofthe-fuel 'pipeline is located outside\nof the airJ)ort fence line .. The pipeline does not cross an offshore area or a waterway that is used for\ncommercial navigation.\n287 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\n\n<<<PAGE 3>>>\n\nThe City of Bangor is respectfully requesting your review and ruling of the request for an exemption from\nDOT regulations as defined by the above criteria. Please fee l free to contact me should you have any\nquestions or concerns. We appreciate your review and guidance on this matter.\nVery Kind Re~,\n'7) _\n\\ /\nlft 4~?\nAnthony P. Caruso Jr., C.M.\nAirport Director\nBangor International Airport\nAttachment: Fuel Truck Technical specification designation.\nCC: Byron Coy P.E., Director\nKaren Gentile, Community Assistance & Technical Services (CATS) Manager\nJohn Theriault, City of Bangor Engineer\nWynne Guglielmo, Environmental Coordinator\nRobbie Beaton, Superintendent of Airport Operations\nGil Merchant, Fuel Farm Supervisor\n\n<<<PAGE 4>>>\n\nl'-1\\1{''\\\\1'10'-\\l \\IIU'IlH 1\nMay 7, 2015\nMr. Steve Nanney, PHSMA\nPHMSA Pipeline Safety\nSouthwest Region Office\n8701 S. Gessner Road, Suite 1110\nHouston, TX 77074\nRe: Bangor International Airport - 12-inch Diameter Jet Fuel Pipeline - Interpretation Letter (2)\nDear Mr. Nanny,\nThe Bangor International Airport (BGR) is pleased to respond to the questions you posed in your email of\nMay 4, 2015 concerning our underground jet fuel pipeline. Please see below and the attached diagram\nfor items which address these questions and concerns.\nDOT Questions & Resoonses:\n1. What is the 12-inch pipeline proposed maximum operating pressure (MOP) in psig? Note: various\nMOPs were in email.\na. The MOP for the system is set at 150 PSI. Our fuel system is designed to shut down\nautomatically if the pressure exceeds 150 PSI. The normal operating pressure is 85 PSI.\n2. What was the maximum and minimum pressure of the 8-hour pressure test?\na. During the DOT hydro test, the starting pressure was 164 PSI. In the first four (4) hours of\nthe test, the pressure increased to 175 PSI, due to thermal expansion. Following the next four\n(4) hours we reduced the pressure to 124 PSI, and it only reached a max pressure of 139 PSI,\nthus confirming a tight pipeline. Max pressure = 175 psi, Min pressure = 124 psi.\n3. How man tests/ inspections were conducted on the pipeline to determine the pipe wall thickness,\ngrade, and seam type? Where were they taken?\na. BGR performed two tests of the pipe thickness as documented. When we replaced a valve at\nlateral # 1, the pipeline was measured for thickness and the seam was checked. We also had the\npipe tested when we repaired the low point drains at lateral tt2 and #3. The 12\" pipe that was\nremoved was sent to our contractor and pipe was measured for thickness and seam checked.\n4. Do you have any other information on the pipe properties?\na. No additional documentation has been discovered. However, we do have blueprints of the\npipeline from 1956, but they do not contain and pipe specifications.\n5. Will the pump be located at the end of the pipeline just prior to the pipeline tying into the tank near\nthe airport ramp?\n\n<<<PAGE 5>>>\n\na. We plan to locate the pump inside the fence line on the 10\" pipeline that is connected to the\n12\" pipeline in lateral #5. The pump will be located on the inlet piping, downstream of the filter\nvessels, behind the containment building.\n6. What is the elevation difference between the starting and endings points of the pipeline?\na. The low points of the fuel system are at laterals #3 and #4. Both ends of the line are slightly\nhigher than those points. This is where we drain the line to empty the line for maintenance.\nb. Elevations are provided on the attached diagram.\n7. Do you have an elevation profile along the pipeline route?\na. Elevations are provided on the attached diagram.\nPlease review the enclosed material and let me know if you have any questions or need any additional\ninformation for your determination for exemption status. Thank you for your consideration of this\nmatter.\n- ~\nAnthony P. Caruso Jr., C.M.\nAirport Director\nBangor International Airport\n• AttachmentS: Bangor International Airport - Proposed Pump Station aerial diagram .\nCC: John Gale, Director, Standards & Rule Making\nByron Coy P.E., Director\nKay Mciver, PHSMA\nKaren Gentile, Community Assistance & Technical S ervices (CATS) Manager\nJohn Theriault, City of Bangor Engineer\nWynne Guglielmo, City of Bangor Environmental Coordinator\nRobbie Beaton, Superintendent of Airport Operations\nGil Merchant, Fuel Farm Supervisor\n\n<<<PAGE 6>>>\n\nBANGOR INTERNATIONAL AIRPORT\nJet Fuel Pipeline (including Lateral Control Pits)\nand Proposed Pump Station\n1\" = 400'\n@ 8.5x11\nApril 2015\nby scg\nFeet\n0 125 250 500 750 1,000\n\n<<<PAGE 7>>>\n\nBANGOR INTERNATIONAL AIRPORT\nJet Fuel Pipeline Elevations (estimated)\n1\"=400'\n@ 8.5x1 1\nMay 2015\nby scg\nFeet\n0 125 250 500 750 1,000","truncated":false,"body_characters":10376}