Interpretation Response #PI-15-0013 ([Mr. Phillip Archer] [Whiting Oil and Gas Corporation])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Mr. Phillip Archer
Individual Name: Whiting Oil and Gas Corporation
Location State: CO Country: US
View the Interpretation Document
Response text:
Mr. Phillip Archer
Senior Midstream Manager
Whiting Oil & Gas Corporation
1700 Broadway, Suite 2300
Denver, CO 80290-2300
Dear Mr. Archer:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated November 16, 2015, you requested an interpretation of 49 CFR Part 195. You asked if the requirements of Part 195 apply to an 8-inch natural gas liquids pipeline that Whiting Oil and Gas Corporation operates in Weld County, Colorado.
You stated that Whiting Oil and Gas Corporation processes raw oil associated produced natural gas gathered from the Redtail Production Field. The natural gas liquids recovered from the gas is stored in four 90,000 gallon storage tanks. From the tanks, natural gas liquids can be transported away from the plant by truck or by pipeline, and no natural gas liquids is received from truck or pipeline at the plant.
You stated that prior to transportation from the tanks to a PHMSA regulated pipeline, the product enters charge pumps. The charge pumps have a maximum head of 19.5 pound per square inch gauge (psig) with 5 horsepower motors. Next, the natural gas liquids reach shipping pumps that have a maximum head of 1848 psig, where the product is metered. Between the charge pumps and shipping pumps, there are pressure relief devices that are set at 285 psig. Also, after the shipping pumps and metering station, the pressure is set at 2220 psig. Downstream of the metering station is a pressure control valve 9660A that is designed primarily to control the volume from the shipping pumps. Downstream of the pressure control valve 9660A there is a pressure relief device emergency shutdown valve XV 9663 set at 2200 psig. Valve 9660A is the last point of modulated pressure control, while the emergency shutdown valve XV 9663 is the last point of full open-closed automated pressure control and isolation prior to the pipeline going underground.
You stated that the Redtail natural gas liquids line is an 8-inch API 5L X52 ERW FBE steel coated pipeline with a wall thickness of 0.500-inches. The line was installed and pressure tested in 2015 and has a maximum operating pressure of 2220 psig. The line is buried approximately 8-feet below grade and is approximately 0.12 miles in length (647 feet). The pipeline ends at the custody transfer with Tallgrass Energy NGL Pipeline which has a maximum operating pressure of 2200 psig.
You stated that Whiting Oil and Gas Corporation has initially designated the inlet of the shipping pumps as the start of transportation and the beginning of PHMSA jurisdiction on hazardous liquid assets or the last point of pressure control depending on the configuration of the hazardous liquid asset. The shipping pumps’ inlet jurisdictional point is being initially used by Whiting Oil and Gas Corporation because the shipping pumps are devices that can affect the pressure on the pipeline and Whiting Oil and Gas Corporation is using its most conservative interpretation while awaiting a determination from PHMSA. You further clarified that the charge pumps alone cannot send the natural gas liquids down the pipeline. Also, the shipping pumps have a maximum head pressure of 1848 psig which is less than the 2220 psig maximum operating pressure of the pipeline. Accordingly, the shipping pumps cannot overpressure the pipeline as described in § 195.406(b). Whiting Oil and Gas Corporation proposes to use emergency shutdown valve (ESD) XV 9663 as the jurisdictional point because ESD XV 9663 is the last point of pressure control by automated isolation upstream of the pipeline. Therefore, you asked if the ESD XV 9663 is where the PHMSA regulations start.
PHMSA agrees with the Whiting Oil and Gas Corporation initial assessment that the inlet (suction) of the shipping pumps is the starting point of transportation and regulated under Part 195. Also, this point is the beginning of PHMSA regulated pipeline because the shipping pumps are the closest devices to the storage tanks that can affect the safety of the pipeline. Therefore, the pipeline is regulated under 49 CFR Part 195 beginning at the shipping pumps.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,