{"operation":"document","citation":"PI-80-003","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1980-01-18","effective_on":null,"summary":"PI-80-003 response to Memo: Internal concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-003.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-003.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-003","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/PI80003.pdf","body":"<<<PAGE 1>>>\n\n1\nMEMORANDUM\nDate: January 18, 1980\nSUBJECT: CPF-5027\nFROM: Chief, Pipeline Safety Enforcement Division, DMT-13\nTO: Associate Director for Operations and Enforcement,\nDMT-10\nI have reviewed the data in the file resulting from an inspection and noncompliance\naction against Union Oil Company of California (CPF-5027), the results of a\nconference held on July 10, 1979, and subsequent data submitted by the operator\nby letter of July 16, 1979. From the analysis of this data, I have determined that\nthe pipeline referenced in this compliance action is a gathering line and is not\nsubject to the regulations of Part 192.\nEach pipeline gathering system is unique and because of this, in developing the\nPart 192 definition of gathering line, DOT and industry were unable to arrive at a\nprecise definition. Since it is not precise, we must rely on our judgement using the\ngenerally accepted industry and government definitions as guidelines. I have\nprincipally used the following definitions as the basis for my determination:\nGathering System: The network of pipelines which carry gas from the well\nto the processing plant or other separation equipment.\nDefinition of Words & Terms\nUsed in the Gas Processing\nIndustry - Gas Processors\nAssoc.\nGas Plant: A gas plant includes any natural gas or natural gas liquid\ngathering facilities and the transportation lines (including compressor\nstations) connecting these facilities to the actual physical plant at which the\nnatural gas or natural gas liquids are processed.\nFederal Register, Vol. 43,\nNo. 184, Thurs., 9-21-78,\nDepartment of Energy\ndal\\192\\3\\80-01-18\n\n<<<PAGE 2>>>\n\n2\nThe definition by the Department of Energy is for economic purposes; however, it does\ndemonstrate that other government agencies do consider gathering lines and processing plants as\npart of the same facility.\nGathering System: The gathering lines, pumps, auxiliary tanks (in the case of oil), and\nother equipment used to move oil or gas from the well site to the main pipeline for\neventual delivery to the refinery or consumer as the case may be. In the case of gas, the\ngathering system includes the processing plant (if any) in which the gas is prepared for\nmarket.\nManual of Oil & Gas Terms\nWilliams & Meyers, 3rd\nEdition\nGathering Line (proposed): A pipeline that transports gas from a point where it is\nproduced to the end of any treatment or other processing necessary to make the gas\ngenerally fit for consumers.\nFederal Register, Vol. 39,\nNo. 188, Thurs., 9-26-74,\nOffice of Pipeline Safety,\nNotice 74-7\nThe OPS proposed definition was subsequently withdrawn because the definition contained many\nwords and phrases which are open to varied interpretation. However, in my opinion, this Union\nOil Company pipeline fits the intent of that definition. The gas in this pipeline prior to removal of\nthe LPG's and natural gasoline (3.46 gal./1,000 feet3) would not meet the generally accepted\nstandards for \"dry\" gas being transported by most transmission companies.\nThe Union Oil Company of California pipeline gathers natural gas and natural gas liquids from\nwells, compresses it, removes water, and then transports the \"wet\" gas to the Santa Clara Valley\nGas Plant where LPG and natural gasoline are extracted from the natural gas. The section of\npipeline between the compressor station and the gas plant is the pipeline addressed in CPF-5027\nand in all of the preceeding [sic] definitions would be considered a gathering line.\nThis pipeline is in a location class 3 due to its location within 300 feet of a building occupied by\n20 or more persons during normal use (Bardsdale Methodist Church). Contrary to the opinion of\nboth the Region and the operator, this location does not be itself make a gathering line or a\nsegment of a gathering line jurisdictional. To be jurisdictional the location must fit the criteria in\nSection 192.1(b)(2) which does not include any direct reference to class location.\ndal\\192\\3\\80-01-18\n\n<<<PAGE 3>>>\n\n3\nSince this pipeline is a nonjurisdictional gathering line, I recommend the penalty assessment be\nwithdrawn, the CPF closed, and the operator be advised of our finding.\nFrank E. Fulton\nTyped Note:\nDMT-13: I agree with your recommendations.\nRobert L. Paullin\n2-25-80\ndal\\192\\3\\80-01-18","truncated":false,"body_characters":4259}