{"operation":"document","citation":"PI-99-0101","title":"Health, Safety, Environmental Quality & Regulatory Affairs Baker Petrolite Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-05-03","effective_on":null,"summary":"PI-99-0101 response to Health, Safety, Environmental Quality & Regulatory Affairs Baker Petrolite Corporation concerning 195.1, 195.2.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1999/g99_05_03_Friedman_195.1_wmx.pdf","body":"<<<PAGE 1>>>\n\nPI-99-0101\nU.S. Department of Transportation\nResearch and\nSpecial Programs Administration\n400 Seventh Street, S.W. Washington, D.C. 20590\nMAY - 3 199\nMr. Brian Friedman\nEnvironmental Engineer\nHealth, Safety, Environmental Quality & Regulatory Affairs Baker Petrolite Corporation\n12645 West Airport Blvd,\nSugar Land, TX 77478\nDear Mr. Friedman:\nThis responds to your inquiry about the hazardous liquid pipeline safety standards in 49 CFR Part 195. You asked if Part\n195 applies to containers of drag reducing additives that are temporarily stored at hazardous liquid pipeline sites and\nthen used to inject additives into hazardous liquid pipelines to reduce line friction and improve flow rate.\nExcept for certain pipeline transportation, Part 195 applies to pipeline facilities and the transportation of hazardous\nliquids associated with those facilities (§ 195.1(a)). The term \"pipeline facility\" means new and existing pipe, rights-of-\nway and any equipment, facility, or building used in the transportation of hazardous liquids or carbon dioxide (§ 195.2).\nIn our view, because the containers in question facilitate the pipeline transportation of hazardous liquids, they are\n\"pipeline facilities\" under the above definition, whether connected to a pipeline or in temporary storage at a pipeline\nsite awaiting connection to a pipeline. When such containers are used in pipeline transportation subject to Part 195,\nthey are subject to\nPart 195 standards governing pipeline facilities.\nIf you need further assistance, please contact Mr. Buck Furrow at (202) 366-4559.\nSincerely,\nRichard B. Felder\nAssociate Administrator for Pipeline Safety\n\n<<<PAGE 2>>>\n\n.:.\nBaker Hughes\n12645 West Airport Blvd.\nSugar Land, TX 77478 USA\nApril 7, 1999\nMr. Buck Furrow\nOffice of Pipeline Safety\nUS Department of Transportation\n400 7th Street SW\nWashington, DC 20590\nSubject: Definition of Pipeline Facility 49 CFR 195.2\nDear Mr. Furrow:\nBaker Petrolite Corporation (BPC) requests clarification of the above definition as it applies to the application of\ntreatment chemicals to pipelines. As per 49 CFR 195.2, a pipeline facility means new and existing pipe, rights-of-way\nand any equipment, facility, or building used in the transportation of hazardous liquids or carbon dioxide. Pipeline or\npipeline system means all parts of a pipeline facility through which a hazardous liquid or carbon dioxide moves in\ntransportation, including, but not limited to, line pipe, valves, and other appurtenances connected to line pipe,\npumping units, fabricated assemblies associated with pumping units, metering and delivery stations and fabricated\nassemblies therein, and breakout tanks.\nBaker Petrolite Corporation provides Drag Reducing Additives (DRA) to crude oil and liquefied petroleum gas (LPG)\ntransporters to reduce pumping costs and maintain product quality. The DRA, injected into the pipeline to reduce\nfluid friction, thus improving the flow of crude oil and refined fuels. The material is a vital component of the pipeline\nfluid and is formulated to meet Department of Transportation specifications. The DRA chemicals are applied directly\nand continuously into the pipeline. The chemical is shipped to the site in DOT- approved !so-containers. These same\ncontainers are used to apply the chemical to the pipeline. When empty, the !so-container is returned to the point or\norigin for refilling.\nIt is clear that, while in transportation to the site, the C-containers are regulated by DOT. BPC would like\nconcurrence that while connected to the pipeline or temporarily stored while awaiting connection to the pipeline\nthe containers are also DOT-regulated in accordance to 49 CFR 195.1. As you are aware, this regulation applies to\npipeline facilities and the transportation of hazardous liquids associated with those facilities in or affecting interstate\ncommerce.\nBPC is requesting concurrence to better define the impact of the Risk Management Program of 40 CFR 68 as\nadministered by the US Environmental Protection Agency on our operations within this portion of our business.\nWe would appreciate your concurrence regarding the above discussion. If you have any questions or need additional\ninformation, please contact me at (281) 275-7477 or Brian J. Keller, P.E., at (281) 275-7434.\nSincerely,\nBrian Friedman\nBaker Petrolite\nEnvironmental Engineer","truncated":false,"body_characters":4350}