{"operation":"document","citation":"PI-93-010","title":"American Petroleum Institute — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-03-01","effective_on":null,"summary":"PI-93-010 response to American Petroleum Institute concerning 194.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93010.pdf","body":"<<<PAGE 1>>>\n\nMarch 1, 1993\nMs. Stephanie R. Meadows\nAmerican Petroleum Institute\n1220 L Street, N.W.\nWashington, D.C. 20005\nDear Ms. Meadows:\nI am writing in response to your telephone discussions with Stacey Gerard concerning the application of\nthe recently published interim final rule on response plans for onshore oil pipelines (58 FR 244; January 5,\n1993; adopting Part 194, Title 49, Code of Federal Regulations). In those conversations, you asked for\nan opinion of whether the new regulations, adopted to implement provisions of Title IV of the Oil\nPollution Act of 1990 (OPA), apply to specific categories of pipelines.\nFollowing are the pipeline categories in your inquiry and our response:\nPipelines used to carry extracted oil and gas from stripper wells to tank batteries.\nUnder Executive Order 12777, and delegations of authorities under that order from the Secretary of\nTransportation to the Administrator of the Research and Special Programs Administration (RSPA) (58\nFR 6193; January 27, 1993), the requirements for spill response planning by operators of on-shore\npipeline facilities (including the submission of plans to RSPA) only apply to transportation-related\nfacilities. We have reviewed the application of Part 194 to pipeline used to carry extracted oil and gas\nfrom stripper wells to tank batteries, and have determined that Part 194 does not apply to those facilities\nbecause they are not transportation-related. This opinion is consistent with the terms of a Memorandum\nof Understanding between the Department of Transportation and the Environmental Protection Agency\n(EPA) (36 FR 24080; December 18, 1971), which was executed to assure effective implementation of the\nFederal Water Pollution Act (which the OPA amends). Under the terms of that Memorandum, we\nconsider the lines at issue to be \"non-transportation-related\" facilities and not subject to the Department's\nregulations. You should note, however, that these lines may be subject to OPA requirements the EPA\nmay adopt.\nNatural gas gathering lines upstream from a processing unit that carry minimal amounts of condensate\nalong with the gas.\nMost gas gathering lines are connected to processing units where heavier hydrocarbons are removed from\nthe gas and sold separately. The small amount of condensates in such lines could not reasonably be\nexpected to cause substantial harm to the environment. Therefore, oil spill response plans covering these\ngas gathering lines would not be required to be filed by February 18, 1993.\nNatural gas transmission lines downstream from a processing unit that may form a minimal amount of\ncondensate in the transmission of the gas.\nDownstream of a processing unit, the gas is in a condition fit for use by gas customers. Beyond the\nprocessing unit the gas generally is transported in a transmission line for delivery to a distribution center\nor storage facility. Natural gas, depending on the volume of gas transported and temperature\ndifferentials, will form small amounts of light hydrocarbons or condensates while being transported in the\ntransmission pipelines because of the recurring compression and subsequent pressure drops. Condensates\n\n<<<PAGE 2>>>\n\nso formed are not considered to cause substantial harm to the environment and oil spill response plans\nwould not be required to be filed by February 18, 1993.\nHydrant distribution systems associated with airport fuel facilities\nPart 194 does not apply to a hydrant distribution system which distributes fuel from a tank battery at an\nairport facility because the hydrant distribution system is a non-transportation-related facility as the term\nis used in the Memorandum of Understanding between the Department of Transportation and the EPA\n(36 FR 24080; December 18, 1971). While Part 194 does not apply to the hydrant distribution system, it\nmay be subject to OPA requirements the EPA may adopt.\nI trust this information is responsive to your request. If you have further questions about this or other\nmatters, please let me know.\nSincerely,\nGeorge W. Tenley, Jr.\nAssociate Administrator for\nPipeline Safety","truncated":false,"body_characters":4092}