{"operation":"document","citation":"PI-79-017","title":"Union Oil Company of California — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-06-01","effective_on":null,"summary":"PI-79-017 response to Union Oil Company of California concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/PI79017.pdf","body":"<<<PAGE 1>>>\n\nMr. Ted Russell\nArea Production Engineer\nUnion Oil Company of California\n730 Executive Plaza East\n4615 Southwest Freeway\nHouston, Texas 77027\nDear Mr. Russell:\nWe were recently asked to respond to your letter of August 11, 1978, to Mr. Robert F. Aubry,\nChief, Southwest Region, asking whether a 6 5/8 inch pipeline running between EHI platforms\n\"A\" and \"B\" is subject to 49 CFR Part 192.\nSince the pipeline lies downstream from platform \"b\"; which is a production facility where\nproduced hydrocarbons are first separated, dehydrated, or otherwise processed, then in\naccordance with Section 192.1, the pipeline is subject to Part 192.\nSincerely,\n/signed/\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\192\\1\\79-06-01\n1\n\n<<<PAGE 2>>>\n\nDepartment of Transportation\nOffice of Pipeline Safety\n6622 Hornwood Drive\nHouston, Texas 77074\nAttention: Mr. Robert F. Aubry\nRe: 6-5/8\" Pipeline between East High Island Block A-334 \"A\" and\"B\" Platforms.\nGentlemen:\nDiscussed in our telephone conversation of July 19, 1978, Union Oil Company of California\nrequests your interpretation of the Department of Transportation Title 49 CFR 192, for natural\ngas pipelines.\nUnion Oil Company of California sent its application for the installation of the subject platform\nconnecting pipeline to the United States Geological Survey on April 14, 1978. (Attachment I -\nLetter from Union;s Mr. Chris Landeck to USGS' Mr. J.B. Lowenhaupt.) Approval for the\npipeline was received by letter dated May 10, 1978 from Mr. Lowenhaupt to Mr. Landeck.\n(Attachment II) The last sentence of the first paragraph on page 2 of this letter states that \"This\napproval is conditioned on the pipeline being designed, constructed, operated, and maintained in\ncompliance with the Department of Transportation regulations 49 CFR 192.\"\nUnion Oil Company of California does not believe that this pipeline should be under the\njurisdiction of the Department of Transportation as stated in the above referenced letter, but feels\nthat it should fall under the jurisdiction of the Department of the Interior. As found in Title 49\nCFR Part 192 - Subpart A-192.1 (b) \"This part does not apply to -- (1) Offshore gathering of gas\nupstream from the outlet flange of each facility on the outer continental shelf where ... produced\nhydrocarbons are first separated, dehydrated, or otherwise processed, whichever facility is farther\ndownstream.\"\nthe following is a brief description of the facility flow pattern indicating the type of service in\nwhich the pipeline will be utilized: (See attachment III for the facility flow pattern.\nEHI A-334 \"b\" Platform has three (3) gas well completions, which are expected to\nproduce between 15 and 20 million cubic feet of gas and 30 to 40 barrels of condensate\nper day. The EHI A-334 \"a\" Platform has thirteen (13) gas well completions, which are\npresently producing 67 million cubic feet of gas and 180 barrels of condensate per day.\nThe \"B\" platform has handling equipment is composed of a production separator, with a\ncapacity of 30 MMCF of gas and 300 barrels of condensate per day, and a test separator,\nwith a capacity of 15 MMCF of gas and 150 barrels of condensate per day. Union Oil\nDB\nC:\\WP51\\INTERPRT\\192\\1\\79-06-01\n2\n\n<<<PAGE 3>>>\n\nCompany elected to equip this platform with both a production and test separator instead\nof just a test separator in order to maximize production form the platform. (If Union had\ndecided to install just the test separator, two (2) of the three (3) completions would have\nhad to be shut-in during the testing period of the remaining completion.) As can be seen\non Attachment III only the condensate is recombined with the gas and sent to the \"A\"\nplatform, any free water is separated and disposed of at the \"B\" platform. Union feels that\nthis will help prevent any possible corrosion in the pipeline connecting the two platforms.\nThe\"A\" platform gas handling equipment is composed of a complete process facility,\nincluding dehydration equipment for the gas and conditioning equipment for the\ncondensate. The capacity of the facility is 120 MMCF of gas and 1200 barrels of\ncondensate per day.\nThe 6-5/8\" pipeline connecting these two platforms was designed to transport this 15-20\nMMCF/D of gas and related condensate from the \"B\" platform wells to the \"A\" platform\nto be combined with the full well stream from the \"A\" platform wells. All of the\nproduction would then be routed through the entire production facility on the \"A\"\nplatform. At the end of the process flow pattern the dehydrated gas is metered and\nrecombined with the metered condensate, before leaving the platform via the High Island\nOffshore System pipeline.\nBased in the above information, as stated earlier, Union Oil Company of California is of the\nopinion that this 6-5/8\" pipeline should not be under the jurisdiction of the Department of\nTransportation, but should be constructed, maintained, and operated in accordance to the\nrequirements of the Department of the Interior.\nThe Department of the Interior's Mr. Doug McIntosh, in a telephone conversation on July 19,\n1978, stated that his department would abide by the interpretation of the Department of\nTransportation on this matter. Therefore, Union Oil Company of California would like you\ninterpretation and/or opinion of this jurisdictional question.\nUnion Oil company of California would appreciate your help and consideration on this matter.\nVery truly yours,\nUNION OIL COMPANY OF CALIFORNIA\nTed Russell, Area Production\nNOTE: ATTACHMENT Engineer\nDB\nC:\\WP51\\INTERPRT\\192\\1\\79-06-01\n3\n\n<<<PAGE 4>>>\n\nC:WPS IUNTERPRT1921119-06-01","truncated":false,"body_characters":5660}