{"operation":"document","citation":"PI-80-0106","title":"Pipeline Safety Interpretation PI-80-0106","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1980-12-19","effective_on":null,"summary":"PI-80-0106 concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0106.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0106.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0106","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/g80-12-19_Solanas_195.1-wmX.pdf","body":"<<<PAGE 1>>>\n\nPI-80-0106\nDecember 19, 1980\nMr. D. W. Solanas\nDeputy Conservation manager\nOffshore Operations Support\nGulf of Mexico OCS Region\nU.S. Department of the Interior\nGeological survey\nP.O. Box 7944\nMetairie, Louisiana 70010\nDear Mr. Solanas:\nThis replies to your letter (OS-5) concerning application of the MOU and part 195 to three offshore pipeline segments in\nthree different case examples.\nAs we interpret the MOU, segments I and II are subject to DOI responsibility, since segments I and II lie upstream from\nthe farthest downstream facility where hydrocarbons are fist processed and under §195.1(b)(5) would be excepted from\nthe requirements of part 195.\nSegment III would be subject to part 195 unless, as you point out, the §195.1(b)(3) exception for pipelines operating at\n20 percent, or less, of SMYS applies. Under the interpretation you mentioned which we gave Alyeska, and “entire\npipelines system” must operate at those stress levels for §195.1(b)(3) to apply.\nWhether segment III is an entire system excepted from part 195 under §195.1(b)(3) depends on its relation to\nconnecting pipelines. If a carrier’s only facilities consist of segments I, II and III or segments II and III, then segment III\nwould be an entire pipelines system, since under the terms of §195.1(b)(5) segments I and II are not subject to part 195.\nHowever, with an operating pressure of less than 20 percent of SMYS in each of the three cases, segment III would be\nexcepted from meeting the requirements of part 195 under §195.1(b)(3).\nIn any of the three cases, if segment III is part of a carrier’s facilities which include the shoreward bound pipeline and\nfacilities other than segment III operate above 20 percent of SMYS, the segment III would not be an entire pipeline\nsystem by itself and would not be excepted under 195.1(b)(3).\nWhere segment III is not subject to part 195, because it still is subject to DOT pipelines safety jurisdiction under the\nterms of the MOU, it would not be within the spirit of the MOU for you to apply DOI’s safety regulations to segment III.\nRather, to resolve any immediate safety problems, we suggest that you advise DOT enforcement personnel in Houston\nof the problems so they can take action as necessary. Looking farther ahead, we do not want any unwarranted gaps in\nthe safety regulations over offshore pipelines for which we are responsible under the MOU. If you will send us a more\ndetailed explanation of the safety problems presented by the low stress level offshore pipelines not currently subject to\npart 195, we will proceed to issue a Federal Register notice requesting public comment on the need for and appropriate\nways to amend part 195 to close the gap.\nSincerely,\nSIGNED\nMelvin A. Judah\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nUnited States Department of the Interior\nGeological survey\nImperial Office BLDG.,3301 N. Causeway BLVD.\nP.O. Box 7944\nMetairie, Louisiana 70010\nIn Reply Refer To ; OS-5\nMaterials Transportation Bureau\nResearch and Special Programs Administration\nAttention: Mr. Melvin Judah\n400 7th Street, SW, Room 8101\nWashington, D.C. 20590\nGentlemen:\nRecent situations have arisen necessitating action by the Department of the Interior (U. S. Geological Survey) to employ\nthe Section, \"Joint Responsibilities\", of the May 6, 1976, Department of Transportation/Department of the Interior\nMemorandum of Understanding. Although your Houston office was notified in each case of these incidents and each\nwas discussed at length, we find it necessary to attempt to better understand your interpretations regarding the\nfollowing cases:\nIn each of the following cases, Segment I is the wellhead assembly, Segment II is the process equipment through which\nall fluids flow, and Segment III is the liquid pipeline located downstream of facilities where produced hydrocarbons are\nfirst separated, dehydrated, or otherwise processed traversing (1) any two platforms, or (2) a platform to a subsea tie-in\nwhich interconnects a shoreward- bound pipeline.\nAlso, SITP is the highest well shut-in tubing pressure, and SMYS is the specified minimum yield strength of the Segment\nIII pipeline.\nCase Segment I Segment II Segment III\n1 SITP > 20% Operating at Operating at\nOf SMYS <20% SMYS < 20% SMYS\n2 SITP < 20% Operating at Operating at\nOf SMYS < 20% SMYS < 20% SMYS\n3 SITP.> 20% Operating at Operating at\nOf SMYS > 20% SMYS < 20% SMYS\nSection 195.1(b)(3) of Title 49 appears to exclude Segment III from the scope of Part 195. However, your interpretation\nletter dated May 26, 1977, to Mr. E. L. Patton of the Alyeska Pipeline Service Company in Anchorage, Alaska, [File 5930-\n1(h)] regarding the Alyeska Pipeline Service Company facilities indicates that an entire system must operate below 20\npercent SMYS to qualify for exception under 195.1(b)(3).\nIn each of the cases described above, please indicate the applicability of Part 195 to each segment. If Part 195 is not\napplicable in all cases, it is imperative that this office be cognizant of such. If DOT Regulations do not apply, and the\ncurrent DOT/DOI MOU does not provide for enforcement of DOI Regulations on these segments, then can no\nenforcement action be legally taken? By enforcement action, we mean steps taken by this office to assure employment\nof safe and environmentally protective procedures, during pipeline installations and repairs.\nIt is recognized that liquid pipelines which operate at 20% SMYS normally operate at very low pressures and do not\npresent serious safety problems if found leaking; however, on offshore platforms, it is not uncommon for heavy wall\nliquid pipeline risers to operate below the 20% SMYS level but yet in fact be operating at 1,000 psi or higher pressures.\nThis office believes that because these pipelines are subject to severe corrosion problems as well as numerous outside\nforces, if this jurisdictional gap does exist, in the interest of both safety and environmental protection, immediate\nconsideration should be given to this matter.\nIf additional discussion is needed, please contact our Pipeline Approval Section at FTS 680-9257.\nSincerely yours,\nD. W. Solanas\nDeputy Conservation Manager\nOffshore Operations Support\nGulf of Mexico OCS Region\n\n<<<PAGE 3>>>\n\nMay 26, 1977\nMr. E. L. Patton\nChairman of the Board\nAlyeska Pipeline Service Company\n1835 S. Bragaw Street\nAnchorage, Alaska 99504\nDear Mr. Patton:\nThis is in furtherance to my letter of March 4, to Mr. Darch, and our meeting in Dallas, Texas, on March 15, 1977,\nregarding Mr. O'Connell's letters to Mr. Knodell of September 16, 1976, and January 25, 1977, concerning the extent of\nDepartment of Transportation (DOT) jurisdiction over (1) pipelines operated at a stress level of 20 percent or less of\nspecified minimum yield strength (SUYS) and (2) gravity flow pipes at the Valdez terminal.\nIn our meeting in Dallas, Texas, attended by members of Alyeska and Materials Transportation Bureau (MTB) staff, we\nreviewed piping drawings of the pipelines that are of concern to Alyeska.\nWith regard to the pipelines which operate at less than 20 percent SMYS, the Alyeska drawing, \"Inventory Line Diagram,\nPump Station No. 8,\" dated October 26, 1976, which was provided us in Dallas, depicts these pipelines in yellow. The\nAlyeska personnel explained that these lines are 12-inch circulating lines within a pump station.\nThe question of DOT jurisdiction over these circulating lines is not dependent on the relationship between the stress\nlevel of those lines and the SMYS of the line pipe in the system. Rather, it depends on whether the circulating lines are\ntransporting crude oil in interstate or foreign commerce.\nMTB staff was informed that these lines are used during startup of a pump and during low flow conditions to keep the\npump case temperature from becoming too high and serve only to draw off crude oil from the discharge side of the\npumps and deliver the oil to a tank. MTB was further informed that this oil is later reintroduced into the upstream side\nof the pump station through a 36-inch relief line.\nBased on this information, it appears that the circulating lines, when used, are taking crude oil out of the transportation\nstream for purposes of aiding in the proper operation of the pump station. It also appears that the circulating lines are\nnot necessary for that part of the operation of the pump station affecting the safe transportation of crude oil in\ninterstate or foreign commerce.\nThis information leads me to conclude that the circulating lines within a pump station are not transporting crude oil in\ninterstate or foreign commerce and, therefore, are not subject to the requirements of 49 CFR Part 195.\nWith regard to the gravity flow lines at the Valdez terminal, the Fluor Ocean Services, Inc., drawing \"D-50-M1558,\" dated\nAugust 9, 1976, Valdez Terminal Crude System - B31.4 49 CFR 195 and drawing “D-50-M1559,” dated August 9, 1976,\nValdez Terminal, Crude, Crude Transfer and Relief ANSI-B31.4, which were provided us in Dallas, depict these pipelines.\nAlyeska personnel advised us in Dallas that the lines which were described in the letters of September 16, 1976, and\nJanuary 25, 1977, were not limited to being used as gravity lines at all times since the tanks could be bypassed and the\ncrude oil could be pumped directly to the ship through these lines from the 4S-inch main line. Consequently, these lines\nare not a unique gravity pipeline system and are in fact a continuation of the pipeline system all the way to the ship\ndocking berths and as such are subject to the requirements of 49 CFR Part 195.\nDrawing D-50-M1559 also indicates in heavy dark lines crude transfer lines, relief lines, and lines from the common\nmanifold or \"feed-in\" line to each tank, MTB was informed that the heavy dark lines indicated pipeline that Alyeska\nconsidered subject to ANSI-B31.4 but not 49 CFR Part 195. However, during the Dallas meeting, Alyeska personnel indi-\ncated that the drawing, in relation to the relief lines, was in error because Alyeska correctly considers such relief lines to\nbe subject to 49 CFR Part 195. In addition, Alyeska personnel sought MTB concurrence on the non-applicability of 49 CFR\nPart 195 to the crude transfer lines and the lines from the manifold or \"feed-in\" line to each tank on the basis that these\n\n<<<PAGE 4>>>\n\nlines operate at stress levels of 20 percent or less of the SMYS of the line pipe in the system.\nThe MTB cannot concur that the requirements of 49 CFR Part 195 are not applicable to the lines from the manifold or\n\"feed-in\" line to each tank. Because crude oil is delivered directly from the 48-inch main line to tanks through these lines\nthey are an integral part of the regulated main line system and, therefore, cannot be considered a unique system in\norder to qualify for the exception provided under 49 CFR 195.1(b)(3). As stated in my March 4 letter, The applicability of\nPart 195 is determined not in relation to portions or segments of a pipeline system, but rather in relation to a pipeline\nsystem in its entirety.\" Under 195.1(b)(3) only a “pipeline system,\" as that term is defined in §195.2, that operates at a\nstress level of 20 percent or less of SMYS of the line pipe in the system is excepted. This exception is not applicable to\nsegments of a system that meet these criteria unless the entire system also meets these criteria.\nAs to the crude transfer lines that Alyeska considers subject to ANSI-B31.4 but not 49 CFR Part 195, I have concluded\nthat the regulations do not apply. These lines are used exclusively to transfer crude oil from one tank to another. Like\nour discussion regarding the 12-inch circulating lines, MTB believes that DOT jurisdiction over the crude transfer lines is\nnot dependent on whether they qualify for the exception under §195.1(b)(3). Rather, MTB believes that during the\ntransfer of crude oil from one tank to another the oil is not in interstate or foreign commerce and, therefore, the\npipelines used to accomplish that transfer are not subject to the requirements of 49 CFR Part 195.\nI trust that these findings will prove helpful to Alyeska in assuring continued compliance with DOT's liquid pipeline safety\nregulations.\nIn anticipation of my conclusion that the regulations are applicable to the \"gravity flow* lines at the Valdez terminal and\nhaving been advised by the Department of the Interior's Alaska Pipeline office that it had issued nonconformance\nreports on 13 girth welds at the terminal, Mr. Cesar DeLeon, Acting Director of the Office of Pipeline Safety Operations,\nmet with management and senior staff personnel of Alyeska, the Alaska Pipeline Office, and Mechanics Research Incor-\nporated, in Valdez, Alaska, on May 12, 1977, to discuss the Valdez terminal lines and conduct an onsite inspection of\nthese girth welds. Mr. DeLeon will communicate directly with Mr. M. J. Robinson of Alyeska Quality Assurance regarding\nhis evaluation of the circumstances with respect to each of the repaired welds.\nSincerely,\nJames T. Curtis, Jr.","truncated":false,"body_characters":13026}