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Interpretation Response #PI-09-0009 ([Marathon Pipe Line L.L.C.] [Mr. Richard A. Abraham])

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

Interpretation Response Details

Response Publish Date:

Company Name: Marathon Pipe Line L.L.C.

Individual Name: Mr. Richard A. Abraham

Country: US

View the Interpretation Document

Response text:

June 24, 2009

Mr. Richard A. Abraham

Pipeline Safety Compliance Professional

Marathon Pipe Line L.L.C

539 South Main Street

Findlay, OH 45840-3295

Dear Mr. Abraham:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated September 29, 2008, you requested an interpretation of 49 CFR 192.1 and 192.3 of the Federal pipeline safety regulations. You asked whether a pipeline you use to supply gas to an offshore platform is subject to Part 192. You also asked what § 192.3 definition would apply to the pipeline if PHMSA determined that the line is subject to Part 192. You indicated that you believe that Part 192 does not apply to your pipeline because you are the consumer, transporter and owner of the gas used on the platform. Finally, you stated that your position was supported by two interpretations issued by the Materials Transportation Bureau, a PHMSA predecessor agency, in the 1980's.

Pursuant to Chapter 601, Title 49, United States Code, PHMSA has responsibility for protecting against risks to life, property, and the environment posed by pipelines. In carrying out its responsibilities, PHMSA has established design, construction, operation, and maintenance standards and regulations for gas pipelines and has responsibility for enforcing these requirements. Under 49 U.S.c. 60102(a)(l) and (2), these standards and regulations apply to both "pipeline transportation" and "pipeline facilities." The definition of pipeline transportation includes the gathering, transmission, and distribution of gas, and the definition of a gas pipeline facility includes "a pipeline, a right-of-way, a facility, building, or equipment" to be used in transporting gas (49 U.S.C. 60101 (a)(3».

You provided the following background information in support of your request: Marathon owns and maintains an offshore platform (Spark Platform) that is no longer used to produce gas. The Spark Platform receives gas from a 6-inch offshore pipeline which becomes a 3-inch onshore pipeline (collectively, "Platform Line"). Marathon operates the Platform Line at 990 psig. Gas usage is metered on the platform and typically indicates platform consumption of 300 mcf per month. The Platform Line receives gas from a 16-inch transmission line. Marathon operates the transmission line and jointly owns the line with another company. The transmission line transports gas produced by Marathon, the second owner and, occasionally, other companies.

Our responses to your requests for interpretation are as follows:

1. Question - Does Part 192 apply to the Platform Line?

Answer- Yes. The Pipeline Safety Laws (49 U.S.C. 60101 et seq.) and 49 C.F.R. Part 192 provide for safety regulation of pipeline facilities and the transportation of gas, without regard to who owns the gas. A sale of the gas is not required. Therefore, gas can be in transportation even if it is produced, transported and consumed by the same entity. I

2. Question - What § 192.3 definition applies to the Platform Line?

Answer - Based upon the information you provided, the Platform Line is a transmission line because it is operated at a hoop stress of 20 percent or more of SMYS. Section 192.3 provides that a transmission line means a pipeline, other than a gathering line, that: (l) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not down-stream from a distribution center; (2) operates at a hoop stress of 20 percent or more of SMYS; or (3) transports gas within a storage field. The Platform Line is not a gathering line because it does not transport gas ·from a production well to a transmission line. The Platform Line is operated at a pressure of 990 psig, a hoop stress of 20 percent or more of SMYS.

I hope that this information is helpful to you. If I can be of further assistance, please contact me at (202) 366-4046.


John A. Gale

Director, Office of Regulations

Regulation Sections

Section Subject
192.1 What is the scope of this part?
192.3 Definitions