Pipeline Safety Interpretation PI-78-0106

Page 1PI-78-0106 September 21, 1978 Mr. Warren McDonald, President Tampa Pipe Line Corporation P.O. Box 19201 Tampa, Florida 33686 Dear Mr. McDonald: We have received a letter from Gonzalo Ancira of Ancira Engineering Services, Inc., in response to our letter to you dated July 21, 1978, outlining proposed requirements your Corporation must meet to properly inhibit stress-corrosion cracking on the Tampa-Bartow anhydrous ammonia pipeline. Mr. Ancira's letter indicates that you have no objection to these requirements. In view of the above, please be advised that the order dated July 9, 1978, prohibiting transport of the commodity in the proposed manner is hereby lifted as long as the requirements in our July 21 letter are met. Mr. Ancira raised the question about the Department's regulatory jurisdiction over the pipeline. We believe the pipeline is engaged in foreign commerce, and thus subject to 49 CFR 195, because the only two consignees on the pipeline purchase the commodity directly from a foreign source and there are no other deliveries made to or from the terminal tanks used to store the commodity. Sincerely, SIGNED Cesar De Leon Associate Director for Pipeline Safety Regulation Materials Transportation Bureau#

Page 2Ancira Engineering Services, Inc. Suite 228 Hamilton Hotel P.O. Box 480 Laredo, Texas 78040 August 7, 1978 Mr. Cesar de Leon Associate Director for Pipeline Safety Reg. Material Transportation Bureau Department of Transportation Washington, D. C. 20590 Dear Mr. de Leon: With reference to your letter dated July 2, 1978 to Mr. Warren McDonald, Tampa Bay Pipeline Corporation, we would like to call your attention the following observations in the same sequence as your letter. Tampa Bay Pipeline Corporation will monitor the water content of the Anhydrous Ammonia and will not accept ammonia for shippment which does not meet the Federal requirement of 0.2% water content. Tampa, however; will not be permitted to alter the quality of the product without consent from the shipper and so far the shipper has advised that they have provisions for injecting water into the ammonia system themselves. Tampa Bay Pipeline Corporation has contracted the Thornton Laboratories of Tampa, Fla. to run analysis and monitor all ammonia shipments. The proposed prescribed requirements as outlined in your letter will be meet as follows: 1 - Water content will be 0.20 percent. 2 - Carrier is providing a monitor system and run the necessary analysis of each shipment insure that the shipper has complied with thas requirement. 3 - The carrier has prepared and established written proceedures of the pipeline system in compliance with 195.402 of the minimum Federal Safety Standards for liquid pipelines. Tampa Bay Pipeline accepts full responsibility for the quality of product to be transported and all product not meeting said requirement will not be accepted for shipment. In reviewing the minimum Federal Safety Standars for liquid pipelines with our legal department, it was called to our attention that under subpart A- General 195.1 scope, our pipeline is intrastate and you should not have any jurisdiction if jou claim jurisdiction based on foreign commerce of hazardous material, our legal departament claims that no such foreign commerce exists between the carrier and the shipper nameley (Tampa-RoysterGrace). The fact that some of the ammonia is of foreign origen constitutes foreign commerce at the port of entry between the shippers storage and thevessel making the delivery from a foreign source. Our legal departament advises us that Tampa Bay Pipeline is in no way involved in foreign commerce, if we are, please advise in writting how we can be classified as such. Tampa Bay will comply with all Federal regulations for safety purposes regardless of whether or not we are under your jurisdiction or not. Yours very truly, Gonzalo Ancira#

Page 3July 21, 1978 Mr. Warren McDonald Tampa Pipe Line Corporation P.O. Box 19201 Tampa, Florida 33686 Dear Mr. McDonald: We have received a letter from Gonzalo Ancira of Ancira Engineering Services, Inc., Laredo, Texas, in response to our Order dated June 9, 1978, concerning the potential stress corrosion cracking problem on the proposed Tampa-Bartow anhydrous ammonia pipeline. His letter indicates that the Tampa Pipeline Corporation's plan to inhibit stress corrosion cracking in the pipeline amounts to submitting certifications from the shippers that the water content of the commodity to be transported will not be below 0.30 percent. We do not find that this proposed plan provides an acceptable means of assuring protection against stress corrosion cracking because (1) the means of protection would be under the control of the shipper rather than the carrier and, (2) since water content is subject to change, the plan should include a way to satisfactorily monitor the percentage of water content and to maintain a proper percentage. We propose to prescribe the following requirements to properly inhibit stress corrosion cracking on the Tampa-Bartow pipeline: 1. The water content of anhydrous ammonia transported in the pipeline must not be less than 0.20 percent by volume. 2. The carrier shall monitor the water content and add water into the system if necessary. 3. The operating procedures prepared under Section 195.402 must include provisions for monitoring and maintaining water content. You are invited to submit comments on these proposed requirements by August 31, 1978, so that we may consider them before issuing a final order on the manner in which anhydrous ammonia may be transported in the Tampa-Bartow pipeline. Consistent with Mr. Ancira's proposed action and Section 195.10, you might wish to make arrangements with the shippers to meet proposed requirements 1 and 2 above (e.g., by checking the water content of each shipment prior to its delivery to the pipeline). Doing so, however, would not relieve the Tampa Pipeline Corporation of any responsibility for compliance. Sincerely, SIGNED Cesar De Leon Associate Director for Pipeline Safety Regulation Materials Transportation Bureau#

Page 4Ancira Engineering Services, Inc. Suite 228 Hamilton Hotel P.O. Box 480 Laredo, Texas 78040 June 27, 1978 Mr. Cesar De Leon Associate Director For Pipeline Safety Regulation Material Transportation Bureau Department of Transportation Washington, D.C. 20590 Subject: Tampa Bay Pipeline Corp. Provision for Inhibit Stress Corrosion. Dear Mr. De Leon: Please refer to your letter dated June 9, 1978 to Mr. Warren McDonald on subject matter. We have fully complied with the inhibitor requirement by requiring that all shippers, namely W.R. Grace and Royster furnish the anhydrous ammonia with the inhibitor already in it. We are here-by submitting to you, a copy of such compliance in writting by W.R. Grace, Royster certification will follow. As soon as such certification is in your power, we will request that you kindly remove the restriction placed on our pipeline system. Or advice if there is any other certification you may require from us. Yours Very Truly, Gonzalo Ancira#

Page 5Agricultural Chemicals Group W.R. Grace & Co. P.O. Box 630 Wilmington, N.C. 28401 June 21, 1978 Mr. W. R. McDonald Tampa Bay Pipeline c/o Tampa Pipeline Corporation P. O. Box 19201 Tampa, Florida 33616 Dear Warren: Subject: W. R. Grace Ammonia Terminal, Port Sutton This is to certify that the ammonia received for storage and reshipment through the subject terminal will at all times be 0.30% minimum water content per our anhydrous ammonia agricultural grade product specifications. Sincerely, W. R. Grace & Co. James L. Smith Chief Engineer#

Page 6June 9 Mr. Warren McDonald Tampa Pipe Line Corporation P.O. Box 19201 Tampa, Florida 33686 Dear Mr. McDonald: This refers to our letter dated April 11, 1973, to Mr. Shields D. Clark III, West Coast Engineering Corporation (copy enclosed), regarding a proposed anhydrous ammonia pipeline between Tampa and Bartow, Florida. Our investigation indicates that apparently no provision has been made to inhibit stress-corrosion cracking, a problem of particular concern with this type of pipeline. For this reason, we have determined that the transportation of the commodity in the proposed manner would be unduly hazardous. Therefore, in accordance with 49 CFR 195.6(a), you are hereby ordered not to transport the commodity in the proposed manner until further notice. Please submit your plans to address the stress-corrosion cracking problem. Sincerely, SIGNED Cesar De Leon Associate Director for Pipeline Safety Regulation Materials Transportation Bureau#