{"operation":"document","citation":"PI-16-0006","title":"Statoil Oil and Gas LP — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-12-11","effective_on":null,"summary":"PI-16-0006 response to Statoil Oil and Gas LP.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/56646/statoil-oil-and-gas-lp-pi-16-0006-11-27-2017-part-195432.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\nNOV 2 7 2017\n1200 New Jersey Avenue SE\nWashington DC 20590\nMr. Ronnie Speer\nPrincipal DOT Compliance\nStatoil Oil and Gas LP\n6300 Bridge Point Parkway\nAustin, TX 78730 .\nDear Mr. Speer:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nMay 31, 2016, you requested an interpretation of 49 CFR Part 195. You stated that Statoil is\ncurrently operating a crude oil gathering system in the Bakken area of North Dakota. You asked\nwhether Statoil's Trenton Oil Tank T-1 (Tank T-1) and Alexander Oil Tank T-310 (Tank T-30)\nwould be considered breakout tanks under the 49 CFR Part 195 requirements.\nYou stated Tank T-1 is a vertical crude oil tank with a width of 78 feet, a height of 48 feet, and a\nnormal capacity of37,447 barrels. You stated, under normal operation, Tank T-1 receives crude\noil from an 8-inch pipeline, and that a 4-inch gathering line (\"48 Jackson\") ties into the 8-inch\npipeline before it enters Tank T-1. You stated that custody transfer takes place on site at the\nTrenton Oil facility. You stated that there.are two stations for trucks to unload into Tank T-1.\nYou stated that when the 8-inch pipeline leaves Tank T-1 it becomes a regulated pipeline.\nYou stated Tank T-310 is a vertical crude oil tank with a width of 78 feet, a height of 48 feet, and\na normal capacity of 3 7 ,44 7 barrels. You stated, under normal operation, Tank T-310 receives\ncrude oil from an 8-inch gathering system from the south. You stated that crude oil from the\ntank then flows west into an 8-inch Missouri pipeline. You stated that there are two stations for\ntrucks to unload into the tank. You stated that when the 8-inch pipeline leaves Tank T-310 it\nbecomes a regulated pipeline. In addition, you provided a map of the specific areas for Tanks T-\nl and T-310.\nSection 195.2 defined a breakout tank as:\nBreakout tank means a tank used to (a) relieve surges in a hazardous liquid\npipeline system or (b) receive and store hazardous liquid transported by a pipeline\nfor reinjection and continued transportation by pipeline.\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\n2\nWith regard to Tank T-1, the regulated 8-inch line is shown as bi-directional per the submitted\nmap and is capable of receiving and/or delivering product from, or to, a regulated pipeline. With\nregard to Tank T-310, a portion of the South Alexander gathering line is injecting into the tank\nand is regulated because the pipeline goes through an unusually sensitive area. In this case, the\ntanks are used for injection and continued transportation of crude oil by regulated pipeline.\nTherefore, Tanks T-1 and T-310 meet the definition of§ 195.2(b) and are regulated as breakout\ntanks under applicable requirements pursuant to 49 CFR Part 195. Ifwe can be of further\nassistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR 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\nMr. John Gale May 31, 2016\nPHMSA HQ\nDirector\nPHP-30 Standards & Rulemaking Division\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRef: Statoil Oil & Gas LP Trenton Oil Tank T-1 / Alexander Oil Tank T-310\nDear Mr. Gale:\nStatoil is currently operating a crude oil gathering system in the Bakken area of North Dakota. We are\nlooking for an opinion/interpretation on the regulatory status of our Trenton Oil Tank T-1 and our\nAlexander Oil Tank T-310, more specifically, if the tanks would be considered breakout tanks or not.\nBackground – Trenton Oil Tank T-1\nThe Trenton Oil Tank T-1 is a vertical crude oil tank with a width of 78 feet and a height of 48 feet. The\nnormal capacity is 37,447 barrels.\nUnder normal operation, Trenton Oil Tank T-1 receives crude oil from the 8 inch pipeline. The 4 inch 48\nJackson gathering line ties into the 8 inch Trenton Oil pipeline prior to tank entry which then enters the\nTrenton Oil Tank T-1. Custody transfer takes place on site at our Trenton Oil facility. There are 2 stations\nfor trucks to unload into the tank as well.\nBackground – Alexander Oil Tank T-310\nThe Alexander Oil Tank T-310 is a vertical crude oil tank with a width of 78 feet and a height of 48 feet.\nThe normal capacity is 37,447 barrels.\nUnder normal operation, the Alexander Oil Tank T-1 receives crude oil from the 8 inch gathering system\nfrom the south. Crude oil from the tank then flows west into the 8 inch Missouri pipeline. There are 2\nstations for trucks to unload into the tank as well. The incoming gathering line is classified as non-\njurisdictional and the 8 inch pipeline leaving the tank is classified as jurisdictional (fully regulated).\n\n<<<PAGE 4>>>\n\nA map of the specific areas for each tank is attached below for your reference.\nPlease advise on your interpretation of the classifications of the Trenton Oil Tank T-1 and the Alexander\nOil Tank T-310.\nSincerely,\nRonnie Speer\nPrincipal DOT Compliance\nStatoil Oil & Gas LP\n6300 Bridge Point Parkway\nAustin, TX 78730\nrspee@statoil.com\n(979) 203-4248\n\n<<<PAGE 5>>>\n\nThe Trenton Oil Tank T-1 is depicted as the green circle above. The black lines indicate non-jurisdictional\ngathering lines. The 4 inch black line feeding the Trenton Oil Tank is classified as non-regulated. The 8\ninch line leaving the tank is classified as fully regulated.\n\n<<<PAGE 6>>>\n\nThe Alexander Oil Tank T-310 is depicted as the green circle above. The black lines indicate non-\njurisdictional gathering lines. The black 8 inch line feeding the Alexander Oil Tank is classified as rural\nregulated (South Alexander) in the USA area, however is classified as non-regulated when it enters the\nAlexander Oil Tank. This line is separate from the 8 inch line leaving the tank (yellow/black). The 8 inch\nline leaving the Alexander Oil Tank is classified as fully regulated.","truncated":false,"body_characters":6792}