{"operation":"document","citation":"PI-78-0106","title":"Pipeline Safety Interpretation PI-78-0106","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-09-21","effective_on":null,"summary":"PI-78-0106 concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0106.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0106.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0106","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/g78-09-21_McDonald_195.1-wmx.pdf","body":"<<<PAGE 1>>>\n\nPI-78-0106\nSeptember 21, 1978\nMr. Warren McDonald, President\nTampa Pipe Line Corporation\nP.O. Box 19201\nTampa, Florida 33686\nDear Mr. McDonald:\nWe have received a letter from Gonzalo Ancira of Ancira Engineering Services, Inc., in response to our letter to\nyou dated July 21, 1978, outlining proposed requirements your Corporation must meet to properly inhibit\nstress-corrosion cracking on the Tampa-Bartow anhydrous ammonia pipeline. Mr. Ancira's letter indicates that\nyou have no objection to these requirements.\nIn view of the above, please be advised that the order dated July 9, 1978, prohibiting transport of the\ncommodity in the proposed manner is hereby lifted as long as the requirements in our July 21 letter are met.\nMr. Ancira raised the question about the Department's regulatory jurisdiction over the pipeline. We believe\nthe pipeline is engaged in foreign commerce, and thus subject to 49 CFR 195, because the only two consignees\non the pipeline purchase the commodity directly from a foreign source and there are no other deliveries made\nto or from the terminal tanks used to store the commodity.\nSincerely,\nSIGNED\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nAncira Engineering Services, Inc.\nSuite 228\nHamilton Hotel\nP.O. Box 480\nLaredo, Texas 78040\nAugust 7, 1978\nMr. Cesar de Leon\nAssociate Director for Pipeline Safety Reg.\nMaterial Transportation Bureau\nDepartment of Transportation\nWashington, D. C. 20590\nDear Mr. de Leon:\nWith reference to your letter dated July 2, 1978 to Mr. Warren McDonald, Tampa Bay Pipeline\nCorporation, we would like to call your attention the following observations in the same sequence as your\nletter.\nTampa Bay Pipeline Corporation will monitor the water content of the Anhydrous Ammonia and will\nnot accept ammonia for shippment which does not meet the Federal requirement of 0.2% water content.\nTampa, however; will not be permitted to alter the quality of the product without consent from the shipper\nand so far the shipper has advised that they have provisions for injecting water into the ammonia system\nthemselves.\nTampa Bay Pipeline Corporation has contracted the Thornton Laboratories of Tampa, Fla. to run\nanalysis and monitor all ammonia shipments.\nThe proposed prescribed requirements as outlined in your letter will be meet as follows:\n1 - Water content will be 0.20 percent.\n2 - Carrier is providing a monitor system and run the necessary analysis of each shipment insure that\nthe shipper has complied with thas requirement.\n3 - The carrier has prepared and established written proceedures of the pipeline system in compliance\nwith 195.402 of the minimum Federal Safety Standards for liquid pipelines.\nTampa Bay Pipeline accepts full responsibility for the quality of product to be transported and all\nproduct not meeting said requirement will not be accepted for shipment.\nIn reviewing the minimum Federal Safety Standars for liquid pipelines with our legal department, it was\ncalled to our attention that under subpart A- General 195.1 scope, our pipeline is intrastate and you should\nnot have any jurisdiction if jou claim jurisdiction based on foreign commerce of hazardous material, our legal\ndepartament claims that no such foreign commerce exists between the carrier and the shipper nameley\n(Tampa-RoysterGrace). The fact that some of the ammonia is of foreign origen constitutes foreign commerce\nat the port of entry between the shippers storage and thevessel making the delivery from a foreign source.\nOur legal departament advises us that Tampa Bay Pipeline is in no way involved in foreign commerce, if\nwe are, please advise in writting how we can be classified as such.\nTampa Bay will comply with all Federal regulations for safety purposes regardless of whether or not we\nare under your jurisdiction or not.\nYours very truly,\nGonzalo Ancira\n\n<<<PAGE 3>>>\n\nJuly 21, 1978\nMr. Warren McDonald\nTampa Pipe Line Corporation\nP.O. Box 19201\nTampa, Florida 33686\nDear Mr. McDonald:\nWe have received a letter from Gonzalo Ancira of Ancira Engineering Services, Inc., Laredo, Texas, in response\nto our Order dated June 9, 1978, concerning the potential stress corrosion cracking problem on the proposed\nTampa-Bartow anhydrous ammonia pipeline. His letter indicates that the Tampa Pipeline Corporation's plan to\ninhibit stress corrosion cracking in the pipeline amounts to submitting certifications from the shippers that the\nwater content of the commodity to be transported will not be below 0.30 percent.\nWe do not find that this proposed plan provides an acceptable means of assuring protection against stress\ncorrosion cracking because (1) the means of protection would be under the control of the shipper rather than\nthe carrier and, (2) since water content is subject to change, the plan should include a way to satisfactorily\nmonitor the percentage of water content and to maintain a proper percentage.\nWe propose to prescribe the following requirements to properly inhibit stress corrosion cracking on the\nTampa-Bartow pipeline:\n1. The water content of anhydrous ammonia transported in the pipeline must not be less than 0.20\npercent by volume.\n2. The carrier shall monitor the water content and add water into the system if necessary.\n3. The operating procedures prepared under Section 195.402 must include provisions for monitoring and\nmaintaining water content.\nYou are invited to submit comments on these proposed requirements by August 31, 1978, so that we may\nconsider them before issuing a final order on the manner in which anhydrous ammonia may be transported in\nthe Tampa-Bartow pipeline.\nConsistent with Mr. Ancira's proposed action and Section 195.10, you might wish to make arrangements with\nthe shippers to meet proposed requirements 1 and 2 above (e.g., by checking the water content of each\nshipment prior to its delivery to the pipeline). Doing so, however, would not relieve the Tampa Pipeline\nCorporation of any responsibility for compliance.\nSincerely,\nSIGNED\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation Materials Transportation Bureau\n\n<<<PAGE 4>>>\n\nAncira Engineering Services, Inc.\nSuite 228\nHamilton Hotel\nP.O. Box 480\nLaredo, Texas 78040\nJune 27, 1978\nMr. Cesar De Leon\nAssociate Director For Pipeline\nSafety Regulation\nMaterial Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nSubject: Tampa Bay Pipeline Corp.\nProvision for Inhibit Stress Corrosion.\nDear Mr. De Leon:\nPlease refer to your letter dated June 9, 1978 to Mr. Warren McDonald on subject matter. We have\nfully complied with the inhibitor requirement by requiring that all shippers, namely W.R. Grace and Royster\nfurnish the anhydrous ammonia with the inhibitor already in it.\nWe are here-by submitting to you, a copy of such compliance in writting by W.R. Grace, Royster\ncertification will follow.\nAs soon as such certification is in your power, we will request that you kindly remove the restriction\nplaced on our pipeline system. Or advice if there is any other certification you may require from us.\nYours Very Truly,\nGonzalo Ancira\n\n<<<PAGE 5>>>\n\nAgricultural Chemicals Group\nW.R. Grace & Co.\nP.O. Box 630\nWilmington, N.C. 28401\nJune 21, 1978\nMr. W. R. McDonald\nTampa Bay Pipeline\nc/o Tampa Pipeline Corporation\nP. O. Box 19201\nTampa, Florida 33616\nDear Warren:\nSubject: W. R. Grace Ammonia Terminal, Port Sutton\nThis is to certify that the ammonia received for storage and reshipment through the subject terminal\nwill at all times be 0.30% minimum water content per our anhydrous ammonia agricultural grade product\nspecifications.\nSincerely,\nW. R. Grace & Co.\nJames L. Smith\nChief Engineer\n\n<<<PAGE 6>>>\n\nJune 9\nMr. Warren McDonald\nTampa Pipe Line Corporation\nP.O. Box 19201\nTampa, Florida 33686\nDear Mr. McDonald:\nThis refers to our letter dated April 11, 1973, to Mr. Shields D. Clark III, West Coast Engineering Corporation\n(copy enclosed), regarding a proposed anhydrous ammonia pipeline between Tampa and Bartow, Florida.\nOur investigation indicates that apparently no provision has been made to inhibit stress-corrosion cracking, a\nproblem of particular concern with this type of pipeline. For this reason, we have determined that the\ntransportation of the commodity in the proposed manner would be unduly hazardous. Therefore, in\naccordance with 49 CFR 195.6(a), you are hereby ordered not to transport the commodity in the proposed\nmanner until further notice.\nPlease submit your plans to address the stress-corrosion cracking problem.\nSincerely,\nSIGNED\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau","truncated":false,"body_characters":8649}