{"operation":"document","citation":"PI-95-022","title":"Shell Oil Products Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1995-05-24","effective_on":null,"summary":"PI-95-022 response to Shell Oil Products Company concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1995/PI95022.pdf","body":"<<<PAGE 1>>>\n\nMay 24, 1995\nMs. Joan Korpal\nManager Regulatory Compliance\nShell Oil Products Company\nTwo Shell Plaza\nP.O. Box 2099\nHouston, TX 77252-2099\nDear Ms. Korpal:\nAs you requested, I agree with Shell Oil Products Company that the products pipeline leaving the\nNorco LA refinery is subject to 49 CFR Part 195 including and downstream of the pressure\ncontrol device as indicated on your letter and drawing of April 19, 1995.\nSincerely\nJames C. Thomas\nRegional Director\ncc: Joel Kohler, LA DNR\nw/cy Shell ltr dtd 4/19/95\nWilliam C. Bertges, w/cy\nShell ltr dtd 4/19/95\nbcc: Cesar De Leon w/cy Shell\nltr dtd 4/19/95\nRichard Sanders, TSI w/cy\nShell ltr dtd 4/19/95\ndal/195.1\n95-05-24\n1\n\n<<<PAGE 2>>>\n\nShell Oil Products Company\nApril 19, 1995\nJames C. Thomas, P.E.\nRegional Director\nU.S. Department of Transportation\n2320 LaBranch, RM 2116\nHouston, TX 77004\nSUBJECT: JURISDICTION OF PIPELINE SAFETY REGULATIONS AT\nREFINERIES\nPurpose The purpose of this letter is to request your concurrence with Shell Oil\nProducts Company’ s (SOPC) interpretation regarding the limits of U.S.\nDepartment of Transportation and Louisiana DNR jurisdiction for pipelines\nleaving SOPC’ c refinery at Norco, Louisiana.\nBackground SOPC operates a refinery at Norco, Louisiana. Subsequent to publication by\nRSPA of the “ Regulatory Review - Hazardous Liquid and Carbon Dioxide\nPipeline Safety Standards” , in June, 1994, SOPC has reviewed the extent of\nregulatory jurisdiction of piping at this location.\nPiping covered by this letter This letter covers piping through which products leave the refinery. The lines\nare operated and maintained by Shell Pipe Line Corporation outside the plant,\nand for a short distance inside the plant. Pressure is supplied by the refinery.\nRegulations Hazardous Liquid Pipeline Safety regulations exclude from regulation\n“ transportation of a hazardous liquid or carbon dioxide through . . . refining, or\nmanufacturing facilities, or in-plant piping systems associated with such\nfacilities”\n.\nThe regulation also defines “ in-plant piping system” to mean “ piping that is\nlocated on the grounds of a plant and used to transfer hazardous liquid or\ncarbon dioxide between plant facilities or between plant facilities and a pipeline\nor other mode of transportation, not including any device and associated piping\nthat are necessary to control pressure in the pipeline under 195.406(b).”\nContinued of next page\ndal/195.1\n95-05-24\n2\n\n<<<PAGE 3>>>\n\nSOPC’ s interpretations\nSOPC interprets part 195 of the pipeline safety regulations to mean:\nüjurisdiction of pipeline safety regulations extend upstream, that is, into the\nrefinery, to a device that is necessary to protect the pipeline outside the\nrefinery from overpressure\nüthe existence of additional overpressure protective devices within the plant,\nand for the protection of the piping between the pressure source and the\ndevice which protects the pipeline, does not affect the limits of jurisdiction,\nand\nüa crossing of a single public thoroughfare by otherwise unregulated sections\nof in-plant piping does not affect the extent of jurisdiction.\nSketch attached A sketch of the piping under consideration is attached. This sketch does not\nrepresent any single piping system at the Norco refinery; rather, it combines\nelements of various systems.\nPrevious reviews The interpretations described in this letter were discussed in a February 20,\n1995 meeting between Mike Chauvin and Shawn Hansson of SOPC, Dana\nArabie of the Louisiana Department of Natural Resources, and Bill Bertges of\nthe U.S. Department of Transportation. Bertges and Arabie recommended\nthat these issues be directed to you in writing.\nQuestions If you have questions regarding this subject please call S.H. Hansson at (713)\n241-1751.\nConcurrence requested of these regulations.\nWe request that you provide a written concurrence with SOPC’ s interpretation\nYours very truly\nJoan Korpal\nManager Regulatory Compliance\ndal/195.1\n95-05-24\n3","truncated":false,"body_characters":3963}