{"operation":"document","citation":"PI-94-030","title":"BP Exploration (Alaska), Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-10-11","effective_on":null,"summary":"PI-94-030 response to BP Exploration (Alaska), Inc. concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94030.pdf","body":"<<<PAGE 1>>>\n\nOctober 11, 1994\nBarney V. Dotson\nPrudhoe Bay Field Manager\nBP Exploration (Alaska), Inc.\nP.O. Box 196612\nAnchorage, Alaska 99519-6612\nDear Mr. Dotson:\nFollowing your presentation on September 2, 1994, we considered the applicability of the safety\nregulations in 49 CFR Part 195 to BP’ s pipeline systems on the North Slope. The typical system\nconsists of pipelines that begin at production wells and run to a manifold building where they are\njoined into a larger pipeline. At this building, the flow in each pipeline is alternately routed to a\ntest separator used to meter the gas, oil, and water produced from the wells. All separated fluid is\nrecombined before moving to the larger pipeline. The larger pipeline extends to a separation\nfacility that permanently divides the transported fluid into its gas, oil, and water components.\nFrom the separation facility, each fluid component is transported separately by pipeline, the oil\ncomponent going to the Trans-Alaska Pipeline.\nWith certain exceptions, the regulations in 49 CFR Part 195 apply to the transportation of\nhazardous liquid and carbon dioxide by pipeline in or affecting interstate or foreign commerce.\nThe exceptions relevant to the North Slope systems include offshore production (§ 195.1(b)(5)),\nonshore production (§ 195.1(b)(6)), rural petroleum lines (§ 195.1(b)(4)), and certain low-stress\npipelines (§ 195.1(b)(3)). Based on the definition of “ production facility” in § 195.2, we have\nconcluded that the portion of the system between the wells and the outlet of the separation facility\nconstitutes production that is excepted under § 195.1(b)(5) or § 195.1(b)(6).\nIf the pipeline between the separation facility and the Trans-Alaska Pipeline in 8 inches or less in\nnominal diameter, it is a gathering line as defined in § 195.2. As a gathering line, it would come\nunder the exception in § 195.1(b)(4) to the extent it traverses a “ rural area,” which is also defined\nin § 195.2. If the pipeline is more than 8 inches in nominal diameter but is a “ low-stress pipeline”\nas defined in § 195.2, it may come under the exception in § 195.1(b)(3). This exception covers\nlow stress pipelines that do not transport a highly volatile liquid and that are located in a rural area\noutside a waterway that is navigable in fact and currently used for commercial navigation.\nWe appreciated meeting with you and other members of the BP staff. Please let me know if we\ncan provide any further assistance regarding the Part 195 regulations.\nSincerely,\nCesar De Leon\nDeputy Associate Administrator for\nPipeline Safety\ndal/195.1\n94-10-11","truncated":false,"body_characters":2604}