{"operation":"document","citation":"PI-78-0108","title":"Pipeline Safety Interpretation PI-78-0108","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-11-09","effective_on":null,"summary":"PI-78-0108 concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0108.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0108.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0108","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/g78-11-09_Die_195.1-wmx.pdf","body":"<<<PAGE 1>>>\n\nPI-78-0108\nNovember 09, 1978\nMr. Roy R. Die\nExxon Pipeline Company\nPost Office Box 2220\nHouston, Texas 77001\nDear Mr. Die:\nThank you for your October 13, 1978, letter to Secretary Adams notifying us of your intent to place in service\nyour pipelines from South Pass Block 93A and Mississippi Canyon Block 268.\nSection 195.6 does not require notice in the case of multi-phase gas and oil flow because, as stated in Section\n195.1(b)(1), Part 195 does not apply to a commodity transported in a gaseous state. However, as your letter\nindicates, since the pipelines will be carrying natural gas and crude oil they will be subject to 49 CFR Part 192\nas well as Part 195. Thus, they must comply with the applicable requirements of both Parts and, in the event\nof conflict, the more stringent requirement of either Part.\nSincerely,\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nOctober 13, 1978\nExxon Pipeline Company\nPost Office Box 2220\nHouston, Texas 77001\nMr. Brock Adams\nSecretary, Department of Transportation\nWashington, D. C. 20590\nThis letter is Exxon Pipeline Company's notice of its intention to include natural gas as a transported\ncommodity along with crude oil in the captioned offshore pipelines located in the Gulf of Mexico. The purpose\nof this notification is compliance with the requirements of DOT section 195.6, Transportation of Certain\nCommodities.\nThese pipelines were recently constructed in conformance with Title 49 CFR Part 195, Minimum Federal Safety\nStandards for Liquid Lines. During construction it was learned that natural gas transportation in multiphase\nflow would be required from both South Pass Blk. 93A and Mississippi Canyon Blk. 268.\nThese offshore lines are in federal waters and do not impact in a safety sense on the general public, or to a\nsignificant degree on Exxon employees. The most pertinent aspect of the operation of these pipelines is the\npotential impact on the environment. Thus, the containment, repair, and clean up of the crude oil constituent\nof the multiphase mixtures should be the principle concern of both the DOT and the EPA. In addition, even\nthough the projected (gas/oil) ratios are high the pipelines are extensions of an extensive existing crude oil\npipeline system and from a practical sense they should be operated and managed as liquid pipelines.\nBased on the above considerations, these multiphase pipelines will be operated and reported in accordance\nwith Title 49 CFR Part 195. Operation of the South Pass line is scheduled to begin about November 1, 1978 and\nthe Mississippi Canyon line should begin operation in April, 1979. As the design, II-testing and operating\nconditions for these lines meet the most stringent regulatory requirements of both the gas and liquid\nregulations, we assume the 90 day notice set forth in Paragraph 195.6(a) does not apply.\nRoy Die","truncated":false,"body_characters":2911}