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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-03-0103 ([Enron Pipeline Services Company] [Mr. David L. Johnson])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Enron Pipeline Services Company

Individual Name: Mr. David L. Johnson

Location State: TX Country: US

View the Interpretation Document

Response text:


U.S. Department of Transportation
Research and Special Programs Administration
400 Seventh St., S.W.
Washington, D.C. 20590

JUN 11, 2003

Mr. David L. Johnson
Enron Pipeline Services Company
P.O. Box 188
Houston, TX 77251-1188

Dear Mr. Johnson:

This is in response to your letter of June 18, 2002, in which you request an interpretation of the regulatory status of an EOTT Energy Pipeline Limited Partnership (EOTT) crude oil gathering pipeline system from Rhame Station in North Dakota to Baker Station in Montana.

You allege that this pipeline is non-regulated under 49 CFR 195.1(b)(4), which provides that Part 195, Transportation of Hazardous Liquids by Pipeline, does not apply to transportation of petroleum in onshore gathering lines in rural areas. "Gathering line" is defined at § 195.2, Definitions, as a pipeline of 8-5/8 inches or less nominal outside diameter that transports petroleum from a production facility.

You note that the EOTT pipeline has truck injection pipelines at Rhame Station and at one other location enroute to Baker Station, which you believe does not change the character of the downstream line from gathering. In support of this position you cite the preamble to Amendment 195-36 (effective August 20, 1986), which states that:

[s]o long as the nominal pipe size remains 8 inches or less and the function of transporting petroleum from a production facility is maintained, an in-line surge tank, block valve, or other facility will not change the character of the downstream line from gathering and [t]he only cause for a gathering line to terminate would be upon connection with a non-pipeline facility (e.g., a refinery) or a pipeline larger than 8 inches in nominal diameter.

You also cite a letter from James C. Thomas, Regional Director, Office of Pipeline Safety to Koch Industries (March 26, 1997) that a lateral pipeline from a truck station does not change the status of a non-regulated gathering line.

The Office of Pipeline Safety agrees with your interpretation that the EOTT crude oil pipeline system from Rhame Station in North Dakota to Baker Station in Montana is a non-regulated gathering line under § 195.1(b)(4) because it is less than 8 5/8 inches in nominal outside diameter, transports petroleum from a production facility, and is located in a rural area.

If you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.


Richard D. Huriaux, P.E.
Manager, Regulations
Office of Pipeline Safety

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?