Interpretation Response #PI-11-0005
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. Max Jameson
Sabco Oil and Gas Corporation
34 S. Wynden Drive
Houston, TX 77056
Dear Mr. Jameson:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated April 6, 2011, you requested an interpretation to determine the applicability of the Federal pipeline safety requirements as they relate to the filing of annual reports for your pipeline system. You provided a map of your offshore gas pipeline system and identified the system to include flow lines from wellheads to two platforms, a 10-inch gas transmission line, a 4-inch emulsion line, a 3-inch condensate line, a 4-inch produced water line, and a 10-inch condensate line.
You described your system as a gas gathering operation that transports full-stream product (gas + condensate + produced water) in 2.5-inch flow lines from the wellheads to the two production platforms, where it is then separated. The produced water is either discharged or carried in the 4-inch water line to an onshore disposal well. The separated gas is either sold to a commercial gas transmission line at the platforms, or recombined with the separated condensate and carried to an onshore tank battery by a gathering pipeline. You stated that the pipeline system is only a few miles long and is within the offshore waters of the State of Texas.
Your opinion of a gathering or transmission pipeline is the line that carries products from your offshore platforms to your onshore tank battery. You ask whether you should include the flow lines in the pipeline safety annual reporting requirements.
Per 49 CFR 192.1(b)(1) and 195.1(b)(5), the offshore gathering of gas or crude oil in state waters upstream from the outlet flange of each facility where hydrocarbons are produced or where produced hydrocarbons are first separated, dehydrated, or otherwise processed, whichever facility is farther downstream, is not subject to the pipeline safety regulations in Parts 192 and 195. Accordingly, the 2.5-inch flow lines are not regulated by PHMSA. The 10-inch gas line, as identified by you, is regulated as an offshore transmission pipeline. Since separation first occurs at platform 62, the 4-inch emulsion line is a regulated offshore gas gathering line beginning at the outlet of the separator on platform 62. Likewise, since separation first occurs for the 3-inch condensate line at platform 62 and then the condensate is combined with additional product at platform 49, this line is a regulated offshore hazardous liquid gathering line beginning at the outlet of the separator on platform 62. The 4-inch produced water line would be a production or flow line and is not regulated by PHMSA. Finally, the 10-inch condensate line that connects platform 49 with the onshore tank battery is a regulated hazardous liquids transmission line.
It is important to note that the pipeline system is an intrastate pipeline system regulated by the State of Texas. Therefore, we recommend that you contact the Railroad Commission of Texas (the state"s regulatory agency) for determination of any additional annual reporting requirements and applicable pipeline safety regulations within the state"s regulatory authority.
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, Standards and Rulemaking Division
cc: Texas Railroad Commission
|§ 195.1||Which pipelines are covered by this Part?|