{"operation":"document","citation":"PI-79-030","title":"Shell Pipe Line Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-08-28","effective_on":null,"summary":"PI-79-030 response to Shell Pipe Line Corporation concerning 195.2.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/PI79030.pdf","body":"<<<PAGE 1>>>\n\nMr. R. E. Speckman\nManager, Regulations and Maintenance Standards\nShell Pipe Line Corporation\nTwo Shell Plaza\nHouston, Texas 77001\nDear Mr. Speckman:\nYour letter of July 5, 1979, requested that the Department of\nTransportation clarify the regulatory responsibility for on-line\npipeline transmission pumping equipment located on offshore\nplatforms that contain both production facilities and on-line\ntransportation pumping equipment.\nYou stated that from the Memorandum of Understanding (MOU) between\nthe Department of Transportation and the Department of the\nInterior, you have classified the DOT regulated portion on the\njoint function platform as including the pipeline and its directly\nassociated on-line transmission pumping equipment.\nBy definition (Section 195.2), a pipeline system or pipeline means\nall parts of a carrier's physical facilities through which\ncommodities move in transportation. Once it is established by\napplication of Section 195.1 that the pipeline is under DOT's\njurisdiction, then all subsequent on-line transmission pumping\nequipment is considered part of the pipeline and would be under\nDOT's jurisdiction.\nIf we can be of further assistance, please let us know.\nSincerely,\n/signed/\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\195\\2\\79-08-28\n1\n\n<<<PAGE 2>>>\n\nMr. Cesar De Leon, Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D. C. 20590\nDear Mr. De Leon:\nWe request the Department of Transportation clarify the regulatory\nresponsibility for on-line pipeline transmission pumping equipment\nlocated on offshore platforms that contain both production\nfacilities and on-line pipeline transportation pumping equipment.\nShell Pipe Line operates pipelines for the transportation of\nhazardous liquids in navigable waters on state lands and on the\nOuter Continental Shelf. These pipelines, in some instances, are\nrouted across both production and non-production platforms. At\nsome platforms, produced liquids are injected into the pipeline\nstream. At other platforms, there is on-line pipeline transmission\nequipment that is necessary to maintain the level of pipeline\nliquid flow. In one instance, SPLC operates a pipeline located on\na \"joint function\" platform where produced liquids are injected\ninto the pipeline stream and where separate and distinct on-line\ntransmission equipment maintains pipeline flow at the required\nlevels.\nIt is our understanding from the May 6, 1976, \"Memorandum of\nUnderstanding Between the Department of Transportation and the\nDepartment of the Interior\" that from the outlet flange where\nhydrocarbons are produced, separated, dehydrated, or otherwise\nprocessed, whichever facility is farther downstream, pipeline\nfacilities are regulated by the Department of Transportation,\nincluding subsequent on-line transmission equipment but excluding\nsubsequent production equipment. From this memorandum of\nunderstanding, we have classified the DOT regulated portion on the\njoint function platform as including the pipeline and its directly\nassociated on-line transmission pumping equipment. Further, the\nequipment utilized by the producer in injecting the liquids\nproduced at this platform to our pipeline has been classified as\nproduction equipment which we understand is regulated by the\nDepartment of Interior.\nWe have recently had the DOI indicate nonagreement with our\nunderstanding. Upon a thorough review of the DOT/DOI Memorandum of\nUnderstanding, we do not feel that there is any description that\nDB\nC:\\WP51\\INTERPRT\\195\\2\\79-08-28\n2\n\n<<<PAGE 3>>>\n\nwould lead a reader to an opinion different from our understanding\nof DOT regulation of on-line transmission equipment used for the\ntransmission of liquids to shore. Unfortunately, the illustration\nincluded with the DOT/DOI Memorandum of Understanding does not\nclearly illustrate the case of on-line transmission equipment\nlocated on a platform described as a production platform.\nAccordingly, we furnish as an attachment a suggested modification\nto the illustration included with the DOT/DOI Memorandum of\nUnderstanding that incorporates on-line transmission equipment for\na DOT regulated pipeline on a production platform. We believe this\nmodified diagram better illustrates the pipeline facilities\nregulated by DOT as described in the paragraph headed \"DOT\nResponsibilities\".\nYour assistance in clarifying this matter would be greatly\nappreciated.\nVery truly yours,\nR. E. Speckman, Manager\nRegulations and Maintenance Standards\nATTACHMENT - DIAGRAM\nDB\nC:\\WP51\\INTERPRT\\195\\2\\79-08-28\n3","truncated":false,"body_characters":4654}