{"operation":"document","citation":"PI-76-0105","title":"Pipeline Safety Interpretation PI-76-0105","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-05-26","effective_on":null,"summary":"PI-76-0105 concerning 195.248.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-05-26_LeBlanc_195.248-DBx.pdf","body":"<<<PAGE 1>>>\n\nPI-76-0105\nMay 26, 1976\nMr. J. L. LeBlanc\nManager\nEastern Production Division\nChevron Oil Company\nP.O. Box 6056\nNew Orleans, Louisiana 70174\nDear Mr. LeBlanc:\nThis refers to your letter of March 19, 1976, requesting a waiver from compliance with the 48-inch cover\nrequirements of 49 CFR 195.248(a) regarding the construction of a 12-3/4 inch crude oil pipeline in the Gulf of\nMexico.\nAs Mr. Furrow of this office advised Mr. Gibilterra by phone on April 15, 1976, it appears from the information\ncontained in your letter that the proposed burial method No. 2 would comply with Section 195.248(b) and\nthereby obviated the need for a waiver. Our rationale for this finding is that (a) the difficulties which you\ndescribe in attaining the 48 inches of cover required by Section 195.248(a) represent and “impracticable”\nsituation within the meaning of Section 195.248(b)(1) and , (2) the method of installation and cement bags to\nbe used will provide theaadditional protection required by Section 195.248(b)(2).\nSincerely,\nSIGNED\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 2>>>\n\nChevron Oil Company\nThe California Company Division\nP. O. Box 6056\nNew Orleans, La. 70174 March 19, 1976\nChief, Technical Division Major Pipeline Crossings\nMTP-10 12-3/4” Crude Oil Pipeline\nMaterials Transportation Bureau Main Pass Block 41 Field\nOffice of Pipeline Safety Operations Job CK- 43131\n400 7th Street, Southwest\nWashington, D.C. 20590\nAttention: Mr. Frank Fulton\nGentlemen:\nIn reference to 49 CFR part 195, subpart 195.248, Chevron Oil Company requests permission for a variance\nfrom aforementioned regulation. At present Chevron is engaged in laying a replacement crude oil and water\npipeline from our Main Pass Block 41 Field in the Gulf of Mexico to the shoreline approximately southwest of\nthe field. This line will replace an existing 14\" pipeline that has been abandoned in place due to numerous\nleaks.\nThe approved right of way of this pipeline intersects three other major pipelines (see attached drawing). Two\nof the lines are crude oil pipelines owned by Gulf Oil Company and Marathon Oil Company. The third line is a\nmajor gas transmission line from the Main Pass Area owned by Southern Natural Gas Company. Chevron\nintends to cross over each of these lines. The crude oil lines are being operated at relatively low pressures (less\nthan 300 psig). Both Chevron and its pipeline contractor feel that these crude oil lines can be crossed with a\nminimal risk of pollution and personnel safety.\nHowever, after evaluation of the crossing of the Southern Natural Gas (SNG) pipeline, there appears to be only\ntwo economically feasible alternatives in the method of crossing.\n1. Cross Over and Lower the SNG Pipeline\nThis would be necessary so that Chevron's replacement line can meet the required 48 inch burial of 49 CFR\n195.248. In order to accomplish this crossing it will be necessary to lower the operating pressure on the\nSNG line to a minimum of 300 psig to reduce the risk to personnel if the line was damaged during the\ncrossing or lowering operations. Additionally, this reduced pressure requirement would necessitate six oil\nproducers (Chevron is included in these) to be shut in for whatever time it would take to lower the pipeline\n(and repair any damages) causing a daily curtailment of 130 million cubic feet of natural gas, 89 million\ncubic feet of which is casinghead gas (Producers could elect to flare such gas to remain on production or\nshut in all oil production). With regards to such a loss in production, there would be a significant financial\nloss to SNG, Chevron, as well as the other producers. Thus, this method would be both the most expensive\nand potentially dangerous.\n2. Cross Over but do not Lower the SNG Line\nIn this alternative, Chevron would make the crossing of the SNG line and leave the SNG pipeline\nuntouched. Chevron would then bury its 12-3/4\" line to the maximum depth that would allow minimum\nvertical separation of both lines. Chevron would provide additional pipeline protection over the pipeline\n(cement in bags) equivalent to the minimum required cover of 48 inches.\nThis variance from the required burial will serve to both reduce the hazard to personnel and equipment\nand eliminate the need to curtail production into the SNG pipeline.\nWe anticipate that this crossing will be made on or about April 3, 1976. Your earliest approval of burial\nmethod No. 2 in lieu of the required cover in 49 CFR 195.248 will be appreciated.\nIf you have any questions concerning this request or require additional information, please feel free to contact\nMr. T. V. Gibilterra (1-504-521-5783) or Mr. J. S. Gabert, Jr. (1-504-521-5739) of this office.\nYours very truly,\nJ.L. LeBlanc\nManager\nEastern Production Division\n\n<<<PAGE 3>>>\n\nTO: CDL\nFROM: LMFurrow\nSubj: Chevron's March 19 waiver request.\nWe have four options--\n1. Interpret the 48\" burial requirement of 195.248(a) as inapplicable to offshore pipelines because the\nrule only applies to inland waters.\n2. Interpret the 48\" burial requirement as applicable but that Chevron's proposal No. 2 is within the\nexception of 195.248(b) for impracticable situations.\n3. Interpret the 48\" burial as applicable and grant the waiver.\n4. Interpret the 48\" burial as applicable but deny the waiver.\nRecommendation:\nOption 1, because the regulation is vague as to its offshore applicability and probably couldn't be enforced by\ncriminal penalty.\nL. M. Furrow, MTP-30","truncated":false,"body_characters":5479}