Interpretation Response #PI-16-0006
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Statoil Oil and Gas LP
Individual Name: Mr. Ronnie Speer
Location State: TX Country: US
View the Interpretation Document
Response text:
November 27, 2017
Mr. Ronnie Speer
Principal DOT Compliance
Statoil Oil and Gas LP
6300 Bridge Point Parkway
Austin, TX 78730
Dear Mr. Speer:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated May 31, 2016, you requested an interpretation of 49 CFR Part 195. You stated that Statoil is currently operating a crude oil gathering system in the Bakken area of North Dakota. You asked whether Statoil's Trenton Oil Tank T-1 (Tank T-1) and Alexander Oil Tank T-310 (Tank T-30) would be considered breakout tanks under the 49 CFR Part 195 requirements.
You stated Tank T-1 is a vertical crude oil tank with a width of 78 feet, a height of 48 feet, and a normal capacity of 37,447 barrels. You stated, under normal operation, Tank T-1 receives crude oil from an 8-inch pipeline, and that a 4-inch gathering line ("48 Jackson") ties into the 8-inch pipeline before it enters Tank T-1. You stated that custody transfer takes place on site at the Trenton Oil facility. You stated that there are two stations for trucks to unload into Tank T-1. You stated that when the 8-inch pipeline leaves Tank T-1 it becomes a regulated pipeline.
You stated Tank T-310 is a vertical crude oil tank with a width of 78 feet, a height of 48 feet, and a normal capacity of 37,447 barrels. You stated, under normal operation, Tank T-310 receives crude oil from an 8-inch gathering system from the south. You stated that crude oil from the tank then flows west into an 8-inch Missouri pipeline. You stated that there are two stations for trucks to unload into the tank. You stated that when the 8-inch pipeline leaves Tank T-310 it becomes a regulated pipeline. In addition, you provided a map of the specific areas for Tanks T-1 and T-310.
Section 195.2 defined a breakout tank as:
Breakout tank means a tank used to (a) relieve surges in a hazardous liquid pipeline system or (b) receive and store hazardous liquid transported by a pipeline for reinjection and continued transportation by pipeline.
With regard to Tank T-1, the regulated 8-inch line is shown as bi-directional per the submitted map and is capable of receiving and/or delivering product from, or to, a regulated pipeline. With regard to Tank T-310, a portion of the South Alexander gathering line is injecting into the tank and is regulated because the pipeline goes through an unusually sensitive area. In this case, the tanks are used for injection and continued transportation of crude oil by regulated pipeline. Therefore, Tanks T-1 and T-310 meet the definition of § 195.2(b) and are regulated as breakout tanks under applicable requirements pursuant to 49 CFR Part 195. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
John A. Gale
Director, Office of Standards
and Rulemaking
Regulation Sections
| Section | Subject |
|---|---|
| 195 | TRANSPORTATION OF HAZARDOUS LIQUIDS BY PIPELINE |