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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-17-0002

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

Interpretation Response Details

Response Publish Date:

Company Name: West Virginia Department of Environmental Protection

Individual Name: Ms. Ruth M. Porter

Location State: WV Country: US

View the Interpretation Document

Response text:

October 23, 2017

Ms. Ruth M. Porter
Tanks Program Manager
West Virginia Department of
Environmental Protection
601 57th Street SE
Charleston, WV 25304

Dear Ms. Porter:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated December 28, 2016, you requested an interpretation of the definition of pipeline facility under 49 CFR 192.3 in reference to certain aboveground storage tanks used for brine and other fluids.

You stated that the aboveground storage tanks in question are used by "TransCanada/ [Columbia Pipeline Group] to store brine and other fluids removed in the transportation of gas by pipeline by drip separators and to store oil used to lubricate equipment at TransCanada/ [Columbia Pipeline Group] compressor stations." You stated that "[w]hile these [aboveground storage tanks] are located adjacent to a 'pipeline facility', they are not used to 'transport gas in the pipeline' or to 'treat gas in the pipeline system during the course of transportation'". In addition, you provided documentation and previous PHMSA interpretations to support your request for interpretation. You asked whether storage of brine and other fluids aboveground removed from gas can be considered part of a pipeline facility and, therefore, regulated and inspected under the Federal pipeline safety regulations.

Section 192.3 defines pipeline facility as:

Pipeline facility means new and existing pipelines, rights-of-way, and any equipment, facility, or building used in the transportation of gas or in the treatment of gas during the course of transportation.

Equipment used for removal of water and other impurities as treatment of gas meets the definition of a pipeline facility. However, storage of the waste products (brine and other fluids) removed from gas is not considered a pipeline facility under § 192.3 because after removal, the storage of the fluids is not used in further transportation of the regulated product (gas). In addition, both Parts 192 and 195 do not regulate brine or other non-petroleum waste fluids even if they are transported by pipeline from the storage tanks. Equipment lubricating oil stored at the facility is not regulated by the Federal pipeline regulations if the oil storage tank is not connected to or the oil is not transported by a PHMSA regulated pipeline.

Therefore, PHMSA does not consider the TransCanada/ [Columbia Pipeline Group] storage tanks used to store brine or other waste fluids removed from gas as pipeline facilities, and such storage tanks are not regulated by the Federal pipeline safety regulations.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.



John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.3 Definitions