Interpretation Response #PI-14-0015 ([Legacy Reserves Operating LP] [Mr. Scott Bliss])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Legacy Reserves Operating LP
Individual Name: Mr. Scott Bliss
Location State: WY Country: US
View the Interpretation Document
Response text:
Mr. Scott Bliss
Legacy Reserves Operating LP
P.O. Box 2850
Cody, WY 82414
Dear Mr. Bliss:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated August 8, 2014, you requested an interpretation on your Fourbear Gathering Pipeline System located in Park County, Wyoming and the applicability of 49 CFR Part 195 to this pipeline system. The system transports crude oil from production fields in Park County to the Oregon Basin Station where it enters a pipeline system operated by Marathon. You provided an Applicability Study detailing system specifications and operations.
You described the Fourbear Gathering Pipeline System as a low-stress system operating below 20 percent specified minimum yield strength (SMYS) and located in a rural area. You stated that the Fourbear Gathering Pipeline System is unique in design—telescoping from 6-inch to 8-inch, then 10-inch pipe as it travels between pumps. In addition, while the 6-inch and 8-inch segments of the pipeline are within a quarter mile of an unusually sensitive area (USA), the 10-inch segments of the pipeline system are not within a half mile of a USA. Therefore, you believe that the 6-inch and 8-inch segments of the system are rural, non-regulated gathering and the 10-inch segments of the pipeline are Category 3 low-stress pipeline.
Section 195.1(b)(4) states:
§ 195.1 Which pipelines are covered by this Part?
...
(b) Excepted. This Part does not apply to any of the following:
...
(4) Transportation of petroleum through an onshore rural gathering line that does not meet the definition of a "regulated rural gathering line" as provided in § 195.11. This exception does not apply to gathering lines in the inlets of the Gulf of Mexico subject to § 195.413;
Section 195.11(a) states:
§ 195.11 What is a regulated rural gathering line and what requirements apply?
Each operator of a regulated rural gathering line, as defined in paragraph (a) of this section, must comply with the safety requirements described in paragraph (b) of this section.
(a) Definition. As used in this section, a regulated rural gathering line means an onshore gathering line in a rural area that meets all of the following criteria—
(1) Has a nominal diameter from 6" inches (168 mm) to 8" inches (219.1 mm);
(2) Is located in or within one-quarter mile (.40 km) of an unusually sensitive area as defined in § 195.6; and
(3) Operates at a maximum pressure established under §195.406 corresponding to—
(i) A stress level greater than 20-percent of the specified minimum yield strength of the line pipe; or
(ii) If the stress level is unknown or the pipeline is not constructed with steel pipe, a pressure of more than 125 psi (861 kPa) gage.
Also, for low stress pipelines § 195.12 states:
§ 195.12 What requirements apply to low-stress pipelines in rural areas?
(a) General. This Section sets forth the requirements for each category of low-stress pipeline in a rural area set forth in paragraph (b) of this Section. This Section does not apply to a rural low-stress pipeline regulated under this Part as a low-stress pipeline that crosses a waterway currently used for commercial navigation; these pipelines are regulated pursuant to § 195.1(a)(2).
(b) Categories. An operator of a rural low-stress pipeline must meet the applicable requirements and compliance deadlines for the category of pipeline set forth in paragraph (c) of this Section. For purposes of this Section, a rural low-stress pipeline is a Category 1, 2, or 3 pipeline based on the following criteria:
(1) A Category 1 rural low-stress pipeline:
(i) Has a nominal diameter of 8" inches (219.1 mm) or more;
(ii) Is located in or within one-half mile (.80 km) of an unusually sensitive area (USA) as defined in § 195.6; and
(iii) Operates at a maximum pressure established under § 195.406 corresponding to:
(A) A stress level equal to or less than 20-percent of the specified minimum yield strength of the line pipe; or
(B) If the stress level is unknown or the pipeline is not constructed with steel pipe, a pressure equal to or less than 125 psi (861 kPa) gauge.
(2) A Category 2 rural pipeline:
(i) Has a nominal diameter of less than 8" inches (219.1mm);
(ii) Is located in or within one-half mile (.80 km) of an unusually sensitive area (USA) as defined in § 195.6; and
(iii) Operates at a maximum pressure established under § 195.406 corresponding to:
(A) A stress level equal to or less than 20-percent of the specified minimum yield strength of the line pipe; or
(B) If the stress level is unknown or the pipeline is not constructed with steel pipe, a pressure equal to or less than 125 psi (861 kPa) gage.
(3) A Category 3 rural low-stress pipeline:
(i) Has a nominal diameter of any size and is not located in or within one-half mile (.80 km) of an unusually sensitive area (USA) as defined in § 195.6; and
(ii) Operates at a maximum pressure established under § 195.406 corresponding to a stress level equal to or less than 20-percent of the specified minimum yield strength of the line pipe; or
(iii) If the stress level is unknown or the pipeline is not constructed with steel pipe, a pressure equal to or less than 125 psi (861 kPa) gage.
Based on the information you provided, it appears that you have correctly classified the 10-inch diameter portion of the Fourbear Gathering Pipeline System as a regulated low-stress Category 3 pipeline in accordance with § 195.12(b)(3). With respect to the 6-inch and 8-inch portions of the system, if they continue to meet all other criteria for classification as unregulated gathering lines, they can remain classified as unregulated gathering lines.1 With respect to any line segment that has a diameter change in between pumps, while you would have the option of treating the 6-inch and/or 8-inch portion of that segment as unregulated, we would note that many requirements that would apply to the 10-inch portion, such as cathodic protection, may protect the entire segment and many operators treat an entire line segment running between pump stations as regulated for various purposes including mapping and incident reporting if any portion of the segment is regulated.
If we can be of further assistance, please contact Tewabe Asebe of my staff at 202-366-5523.
Sincerely,
TAsebe:jmd: 64046:03-17-15
Edits:LWhite: 03-25-15 and 03-31-15
cc: PHP-30:OfficialFile:Sharepoint:Website
T:PHP-30:Interps: Open:Legacy-PI-14-0015-09-09-2014-Part 195.0
John A. Gale
Director, Office of Standards
and Rulemaking
1 Nothing in this interpretation letter is intended to express any views about any other representations or conclusions in the August 8, 2014, Hazardous Liquid Pipeline Applicability Study provided with your request.
Regulation Sections
| Section | Subject |
|---|---|
| 195.1 | Which pipelines are covered by this Part? |