{"operation":"document","citation":"PI-96-015","title":"BP Exploration (Alaska) Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-07-22","effective_on":null,"summary":"PI-96-015 response to BP Exploration (Alaska) Inc. concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96015.pdf","body":"<<<PAGE 1>>>\n\n1\nJuly 22, 1996\nMr. James S. Teater\nCounsel to BPXA\nBP Exploration (Alaska) Inc.\nPO Box 196612\nAnchorage, Alaska 99519-6612\nDear Mr. Teater:\nWe have considered your letter of March 29, 1996, concerning certain petroleum blending\nfacilities, known as the Skid 50 Pad. The letter explains why BP Exploration (Alaska) Inc.\n(\"BPXA\") believes the Skid 50 Pad facilities are exempt from the regulations in 49 CFR Part\n195.\nAs you and BPXA staff explained in detail at our meeting on April 9, 1996, the Skid 50 Pad is\nlocated on the Prudhoe Bay field in Alaska between BPXA's oil and gas separation facilities and\nthe Trans-Alaska Pipeline System. At the Skid 50 Pad, natural gas liquids that have been\nstripped from the gas at a Central Gas Facility are blended with the separated oil. Because of\nvapor pressure limitations, blending is necessary for the Trans-Alaska Pipeline System to\ntransport the natural gas liquids.\nWe do not agree that the Skid 50 Pad facilities are excluded from Part 195 under § 195.1(b)(6)\nas production facilities. As defined in §195.2, the term \"production facility\" means:\n“ piping or equipment used in the production, extraction, recovery, lifting, stabilization,\nseparation or treating of petroleum or carbon dioxide, or associated storage or measurement.\n(To be a production facility under this definition, piping or equipment must be used in the\nprocess of extracting petroleum or carbon dioxide from the ground or from facilities where CO2\nis produced, and preparing it for transportation by pipeline. This includes piping between\ntreatment plants which extract carbon dioxide, and facilities utilized for the injection of carbon\ndioxide for recovery operations.”\nAlthough the function of the Skid 50 Pad is to prepare petroleum (the natural gas liquids) for\ntransportation by the Trans-Alaska Pipeline System, blending is not one of the operations that\ncharacterizes a facility as a production facility under the definition. The characterizing\noperations are all listed in the first sentence of the definition. Piping or equipment must be used\nin one of these operations to qualify as a production facility. The parenthetical reference to the\nprocess of extracting petroleum from the ground and preparing it for transportation by pipeline\nis meant to clarify and limit the application of this list of operations. (51 FR 15005; April 22,\n1986).\nNeither are we persuaded that the Skid 50 Pad facilities are excluded from Part 195 under\n\n<<<PAGE 2>>>\n\n2\n§195.1(b)(6) as manufacturing facilities. Although Part 195 does not define manufacturing\nfacilities, furthering pipeline transportation is not the primary function of such facilities. The\nSkid 50 Pad facilities are operated primarily to further the transportation of natural gas liquids\nby pipeline. In this sense, the Skid 50 operation does not differ from typical pipeline operations\nin which an interface mixture is blended with a petroleum product to further the pipeline\ntransportation of the interface mixture. Facilities used for this interface blending are covered by\nPart 195.\nWe hope this opinion is helpful. Please let me know if you have any further questions about the\nPart 195 regulations.\nSincerely,\nCesar DeLeon\nDeputy Associate Administrator\nfor Pipeline Safety\ncc: Edward J. Ondak\nMark Major, Arco Alaska, Inc.\nB.Furrow:brw-(202)366-4395,07/08/96\nCC:DPS-1,2,10,20,Region\nTSI-E-Mail,State Mailing,Waiver,teater2.195","truncated":false,"body_characters":3428}