{"operation":"document","citation":"PI-76-004","title":"BASF WYANDOTTE Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-01-26","effective_on":null,"summary":"PI-76-004 response to BASF WYANDOTTE Corporation concerning 192.5.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76004.pdf","body":"<<<PAGE 1>>>\n\nMr. Cesar DeLeon, Acting Director\nOffice of Pipeline Safety\nDepartment of Transportation\n2100 Second Street SW\nWashington, D.C. 20590\nDear Mr. DeLeon:\nAt a recent meeting in your office I agreed to formally request interpretations of the Gas Pipeline\nRegulations as they relate to facilities at our Geismar, Louisiana Works. The regulations are\nwritten to describe residential areas and require interpretation when applied to chemical plant\nfacilities. The buildings and areas described below may be found on the attached portion of our\nsite plan drawing. In the present preliminary design phase, the areas shown represent the best\nguess of building areas according to the scale noted.\nSection 192.5(c) uses the phrase \"intended for human occupancy.\" We request your\ninterpretation as applied to the following:\n1. Administration Building (ADMIN) - Normal daytime occupancy is thirteen people, plus\nvisitors, plus locker room facilities for sixty-two men on day shift and twenty men on the\nodd shifts. This means a normal occupancy at beginning and end of the day shift of\nninety-five people. Between second and third shifts, the combined occupance is forty\npeople. In addition to the above questions, is this also considered normal occupancy by\nmore than twenty people?\n2. Warehouse (WHSE) - The warehouse will be used for the storage of equipment and\nsupplies. It will not have continuous occupancy but will have frequent in and out usage\nfor storage and withdrawal of materials.\n3. Maintenance Building (Maint) - Normal occupancy of this building will be up to forty-four\nmen on day shift and some lesser number during second and third shifts.\n4. Control House - This building will be occupied on a continuous basis with twelve men on\nday shift and approximately eight men on the off shifts.\n5. Boilers, Unit 1300 - Each of the three initial boilers, designed for alternate coal firing, will\nbe approximately 55 feet in height and will have approximately five platform levels. Two\nor three operators will be assigned on each shift for continuous operation.\nDB\nC:\\WP51\\INTERPRT\\192\\5\\76-01-26\n1\n\n<<<PAGE 2>>>\n\n6. Process Units (Units 100 and 200) - the process units will consist of multiple level\nstructures, housing process equipment such as reactors, columns, rotating equipment,\ntanks etc., and manned on a continuous basis by one or more people per unit. Each unit\nwill consist of multiple independent structures, some roofed, such as compressor house,\nvacuum pump house, etc. The structures are typical of chemical process plants and are\ncomparable in function and manning to those found in petroleum refineries. (If the\nprocess units are determined \"for human occupance,\" should each independent structure\nor each level of structure be considered a unit in determining the class location?)\n7. Meter Buildings - These are masonry block buildings housing ga metering equipment but\nnot normally occupied. The buildings are regularly visited for meter reading, calibration,\nand other maintenance activities.\nSection 192.5 (d)(2)(ii) refers to \"a small, well defined outside area that is occupied by twenty or\nmore people during normal use-----.\" The parking lot adjacent to the administration building is\ndesigned for 150 cars. The normal daytime use will be ninety people plus visitors, and the off-\nshifts will have twenty people. Similar to the case of the administration building, at either end of\nthe day shift, the normal count of people will be 110, and between the odd shifts it will be a total\nof forty.\n8. - Does the above described lot fall within the definition of a Class 3\nParking Lot location?\nWe will appreciate receiving your interpretations of these buildings and lot as they relate to\npipeline class locations. Your opinions will enable us to anticipate possible pipeline changes and\nthe resultant construction activity within our plant areas.\nI thank you for the courtesy extended to me on my visit to your office, and will look forward to\nreceiving your opinions in the above matters.\nVery truly yours,\nBase Wyandotte Corporation\nJohn W. Milroy\nChief Engineer - Design\nDB\nC:\\WP51\\INTERPRT\\192\\5\\76-01-26\n2\n\n<<<PAGE 3>>>\n\nMr. John W. Milroy\nChief Engineer - Design\nBASF WYANDOTTE Corporation\nWyandotte, MI 48192\nDear Mr. Milroy:\nThis is in response to your letter dated January 22. 1976, regarding interpretations of the Office of\nPipeline Safety Operations (OPSO) rules and regulations, specifically Section 192.5, Class\nlocation. Contrary to the statement in your letter, OPSO regulations were not written to just\ndescribe residential areas. They are intended to include all types of locations including office\nbuildings, factories, outside recreation areas, etc. Your plant facilities can be induced within a\nclass location definition.\nAs set forth in Section 192.5 of the regulations, the class location of a pipeline is determined by\nthe number of buildings intended for human occupancy within the class location unit, the normal\nhuman occupancy, and the number of stories of those buildings.\nOPSO analysis of your plant diagram and corresponding description of facilities indicates that all\nof your eight buildings or units are intended for human occupancy of more than 20 person.s\nTherefore, this area appears to be in at least a Class 3 location (refer to Section 192.5(d)(2). We\ncannot determine the class location for the areas adjacent to the other buildings from the data\nprovided since that determination will depend on the building count in the remainder of the class\nlocation unit.\nFor purposes of determining class location, we do not consider the platform levels of the\nindustrial facilities described in your letter to be the same as \"stories above ground\" set forth in\nSection §192.5(c).\nIf the pipeline is designed and qualified to meet the present day class location requirements then as\nyour plant develops and more units are actually built, the pipeline may need to be re-evaluated to\ndetermine if it satisfies the operating requirements for the new class location or it may require\nrequalification or operating changes. As an alternate you may design and qualify the pipeline now\nto meet the most severe class location requirements that may be anticipated for the future then\nincrease in class location will have minimal effect on the operation of the pipeline, This is a\nprocedure many operators follow. Requirements for class location changes are detailed in\nSections 192.609 and 192.611 of the regulations.\nDB\nC:\\WP51\\INTERPRT\\192\\5\\76-01-26\n3\n\n<<<PAGE 4>>>\n\nOPSO regulations prescribe safety goals to be achieved, while permitting pipeline operators the\nflexibility of choosing the best method of accomplishment. As this relates to you interest in class\nlocations, the regulations do not limit the number of buildings, units, or occupants. Instead, they\nprescribe safety requirements which vary by degree in many instances according to the\ncharacteristics of a pipeline's location.\nWe trust that this has answered your particular questions.\nIf we can be of further assistance, please let us know.\nSincerely,\n/signed/\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nNOTE: DIAGRAM ATTACHED\nDB\nC:\\WP51\\INTERPRT\\192\\5\\76-01-26\n4","truncated":false,"body_characters":7208}