Interpretation Response #PI-15-0005

Interpretation Response Details

September 28, 2015

Mr. Anthony P. Caruso Jr., C.M.
Airport Director
Bangor International Airport
73 Harlow Street
Bangor, Maine 04401

Ref. No. PI-15-0005

Dear Mr. Caruso:

In response to the City of Bangor request of August 17, 2012, by letter dated February 18, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA) provided the City of Bangor with information concerning the regulatory status of a hazardous liquid pipeline that transports jet fuel from a tank facility to the fuel hydrant system at the Bangor International Airport. The February 18, 2014, letter advised the City of Bangor that the exemption in 49 CFR 195.1(b)(3)(ii) for certain low stress pipelines that serve terminal facilities does not apply to the pipeline.

In a subsequent letter to PHMSA dated March 25, 2015, you stated that the city is evaluating options to alter its pipeline from a pressurized system to a gravity type system. The city would relocate the pumps downstream to a location inside the airport's fence line. The resulting relocation would, by your evaluation, create a low-stress gravity feed system.

In addition, in a May 7, 2015, letter you responded to questions asked by Mr. Steve Nanney of PHMSA's engineering staff. One of your responses provided PHMSA with an elevation profile of the pipeline. The elevation profile shows the lowest elevation point to be in the middle of the pipeline. Also, flow into the pipeline from the storage tank would involve the assistance of a remote suction pump. Based on the information you provided on the elevation profile and the use of a suction pump, the pipeline would not be considered a gravity pipeline.

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

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections