Regulated or not? §195.1(b)(3)(ii)

When is a hazardous liquid line not regulated?  If it meets the exception criteria in §195.1(b).

The attached interpretation explains one such exception.

Nov 7, 2014

 

Mr. Mark C. Wiggin
Engineering and Development Manager
Brooks Range Petroleum
510 L Street, Suite 601
Anchorage, AK 99501

Dear Mr. Wiggin:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) received on January 16, 2014, you requested an interpretation on whether two 6-inch diameter pipelines that Brooks Range Petroleum Company (BRPC) is planning to build in the Southern Miluveach Unit on the North Slope of Alaska would qualify for an exemption from the 49 CFR Part 195 pipeline safety regulations.

You stated that BRPC plans to build a 6-inch diameter oil pipeline and a 6-inch diameter seawater pipeline in early 2015 as part of a future oilfield development.  Both pipelines will be elevated above the tundra at a level of approximately 7 feet and will be supported on shared piles for the length of the lines.  The total length of each pipeline will be about 1,000 feet.  These planned 6-inch pipelines will connect a future 15,000 barrel oil per-day Mustang central process facility to be located on the Mustang Pad to an existing Alpine Oilfield sales oil pipeline and an existing Alpine seawater pipeline.

The main BRPC Mustang process facility will produce sales quality crude that will be transported to market by the proposed 6-inch oil pipeline with a proposed tie-in to an existing   14-inch Department of Transportation  regulated Alpine Transportation Company (ATC) crude oil pipeline.  Seawater will be transported from Kuparuk River Unit by the proposed 6-inch water pipeline and a proposed tie-in to an existing 12-inch Alpine seawater pipeline.  You asked whether the new pipelines would be exempt from the 49 CFR Part 195 regulations under the exemption set forth in § 195.1(b)(3)(ii) for certain low stress piping.

With respect to the seawater pipeline, BRPC does not have to comply with the Part 195 regulations at all because seawater is not a hazardous liquid.  Therefore, while other permits and regulations of other agencies may apply to its construction, the seawater pipeline can be operated without regard to Part 195 regulations.

With respect to the proposed 6-inch diameter oil pipeline, we first note that it does not extend directly from a well or production facility so it is not exempt as a production or gathering line.   It will connect with the 14-inch ATC regulated pipeline and would be considered part of that system for purposes of determining the threshold issue of whether it meets the definition of a low stress pipeline.  Your letter did not indicate whether the 14-inch ATC pipeline is a low stress pipeline or not.

Even if the 14-inch ATC pipeline does meet the definition of a low stress pipeline, the proposed 6-inch pipeline would extend from a processing facility.  Section 195.1(b)(3)(ii) states:

195.1  Which pipelines are covered by this Part?…

(b) Excepted.  This Part does not apply to any of the following:

(3) Transportation of a hazardous liquid through any of the following low stress pipelines:

(ii) A pipeline that serves refining, manufacturing, or truck, rail, or vessel terminal facilities, if the pipeline is less than a mile long (measured outside facility grounds) and does not cross an offshore area or a waterway currently used for commercial navigation;

In this case, the 6-inch pipeline, even though it is less than a mile long, does not serve a refining, manufacturing, or truck, rail, or vessel terminal facility.  In fact, the pipeline transports processed crude from the proposed Mustang central process facility to the existing 14-inch diameter DOT regulated ATC pipeline.  Therefore, based on the information you provided, the 6-inch pipeline would be a part of the already regulated pipeline system and does not appear to qualify for the exemption in § 195.1(b)(3)(ii).

If we can be of further assistance, please contact Tewabe Asebe of my staff at 202-366-5523.

Sincerely,

John A. GaleDirector, Office of Standards and Rulemaking

DMS ID# PI-14-0006

All this and more in WinDOT, The Pipeline Safety Encyclopedia.

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