Mid-Continent Pipe Line Company — Pipeline Safety Interpretation

Page 1Mr. H. L. Crawford, Jr. Vice President Mid-Continent Pipe Line Company 907 South Detroit Avenue Tulsa, Oklahoma 74120 Dear Mr. Crawford: Your letter of August 11, 1989, to the Office of Pipeline Safety (OPS), with enclosures, gave notice as required by 49 CFR ?195.8 of your intention to operate hazardous liquid pipelines constructed of a material other than steel pipe. Specifically, Mid-Continent proposes to install and operate certain crude oil gathering lines in Oklahoma City, Oklahoma, using polyethylene plastic pipe. In an earlier communication with Dennis Fothergill of the Oklahoma Corporation Commission, we found the proposed plastic pipelines to be subject to 49 CFR Part 195. Additional information and data concerning this notice were supplied verbally by Mr. Brad Lange to an OPS senior staff engineer on August 22, 1989. Mr. R. D. McKenzie of your company provided additional information and data by letter of August 29, 1989. Also, Mr. McKenzie on September 14, 1989, concurred by telephone with the two lists of regulations included in Enclosures 1 and 2 which must be complied with concerning these pipelines. From the above described sources, the following is our understanding concerning your proposal: E Installation will consist of a total of approximately 38,800 feet of polyethylene plastic pipe. E The pipe will be 3, 4, and 6 inch, SDR-11, PE 3408, Phillips Driscopipe 6400. E The pipe and fittings will be manufactured in compliance with ASTM D2513, "Standard Specification for Thermoplastic Gas Pressure Pipe, Tubing, and Fittings." E Joining of polyethylene pipe will be by heat fusion. E The pipelines will ne installed with a minimum cover of 48 inches. DB C:\WP51\INTERPRT\195\3\89-09-19 1#

Page 2E The pipelines will transport crude oil in a gathering system in a commercial/residential area classified per 49 CFR ?192.5 as Class location 3. E Each Lease Automatic Custody Transfer (LACT) station feeding the system will be equipped with an automatic shut-down which will deactivate the pump to assure the system operates below the maximum design temperature of 100?F. E The pipelines are designed for an estimated life of 50 years. E The plastic pipelines will provide no significant increase in hazards to the water table or any body of water in their normal operation as compared with steel pipelines in the same service. E Design of plastic pipe will comply with 49 CFR ?192.121 with a factor of 0.20 being substituted for the 0.32 factor shown in the equation. E The polyethylene pipelines shall be designed and constructed in accordance with the requirements pertaining to plastic pipelines contained in 49 CFR Part 192 and listed in Enclosure 1 to this letter. Otherwise the pipelines shall comply with the requirements of 49 CFR Part 195 listed in Enclosure 2 to this letter. Based upon the above information and our technical evaluation of the safety of the proposed pipelines, we have determined in accordance with 49 CFR ?195.8 the use and operation of polyethylene plastic pipe in the above described manner would not be unduly hazardous and the transportation may proceed as planned. Sincerely, /signed/ Richard L. Beam Director Office of Pipeline Safety Enclosures DB C:\WP51\INTERPRT\195\3\89-09-19 2#

Page 3ENCLOSURE 1 Sections from 49 CFR Part 192 required for design, installation, testing, and operation of polyethylene plastic pipelines in a crude oil gathering system in Oklahoma City, Oklahoma. Subpart B - Materials 192.59 Plastic pipe 192.63 Marking of materials Subpart C - Pipe Design 192.121 192.123 Design of plastic pipe (modified by using a .20 factor instead of the .32 factor in the equation) Design limitations for plastic pipe Subpart D - Design of Pipeline Components 192.145 Valves 192.191 Design pressure of plastic fittings 192.193 Valve installation in plastic pipe Subpart F - Joining of Materials Other Than by Welding 192.281 Plastic pipe 192.283 Plastic pipe; qualifying joining procedures 192.285 Plastic pipe; qualifying persons to make joints 192.287 Plastic pipe; inspection of joints Subpart G - General Construction Requirements for Transmission Lines and Mains 192.311 Repair of plastic pipe 192.321 Installation of plastic pipe Subpart J - Test Requirements 192.503 General requirements 192.513 Test requirements for plastic pipelines 192.517 Records Subpart L - Operations 192.619 Maximum allowable operating pressure: Steel or plastic pipelines DB C:\WP51\INTERPRT\195\3\89-09-19 3#

Page 4ENCLOSURE 2 Sections of 49 CFR Part 195 required for polyethylene plastic pipelines in a crude oil gathering system in Oklahoma City, Oklahoma. Subpart A - General (all sections) Subpart B - Reporting Accidents and Safety-Related Conditions (all sections) Subpart C - Design Requirements 195.101 Qualifying metallic components other than pipe 195.104 Variations in pressure 195.108 External pressure 195.110 External loads (except for the second sentence in paragraph (a)) 195.118 Fittings Subpart D - Construction 195.202 Compliance with specifications or standards 195.204 Inspection - general 195.206 Material inspection 195.246 Installation of pipe in a ditch 195.250 Clearance between pipe and underground structures 195.252 Backfill 195.256 Crossing of railroads and highways 195.258 Valves: General 195.260 Valves: Location 195.266 Construction records Subpart F - Operation and Maintenance 195.401 General requirements 195.402 Procedural manual for operations, maintenance, and emergencies 195.403 Training 195.404 Maps and records 195.408 Communications 195.410 Line markers 195.412 Inspection of rights-of-way and crossings under navigable waters 195.420 Valve maintenance 195.422 Pipeline repairs 195.424 Pipe movement 195.440 Public education DB C:\WP51\INTERPRT\195\3\89-09-19 4#