Interpretation Response #PI-15-0008
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. John A. Jacobi
Representing Caelus Energy Alaska, LLC
10850 Richmond Avenue, Suite 200
Houston, TX 77042
Dear Mr. Jacobi:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated October 2, 2015, you requested an interpretation of 49 CFR § 195.446 requirements for pipeline control room management. You asked if the requirements of § 195.446 apply to the operation of a pipeline operated by Caelus Energy Alaska that transports diesel fuel (the "Oooguruk line").
You stated the following:
- The line has no sensors or remote controlled valves "outside the fence" of the facility where it originates that affect or could affect the 2-inch diesel line;
- All control functions are performed by personnel with other assigned functions at the Oooguruk tie-in pad or at the Oooguruk drill site;
- The 2-inch diesel line is used only intermittently and for short periods of time (usually only a few hours). When the 2-inch diesel line is in use (either diesel fuel or base oil), it is operated by locally monitoring pressures and flow rates;
- The monitoring is typically not continuous;
- Automatic pressure and/or flow controls (local) are not attached directly to the pipeline to protect the line;
- Caelus has the ability to monitor overall operation of the production facility but not to remotely monitor and operate the 2-inch diesel line; and
- Caelus has no personnel in a control room using a SCADA system to monitor and control operation of the 2-inch diesel line.
Specifically, you asked whether the requirements of § 195.446 apply to the Oooguruk 2-inch diesel line.
Section 195.446 requirements apply to an operator of a pipeline facility with a controller working in a control room who monitors and controls all or part of a pipeline facility through a SCADA system. From the information you provided, it appears that the 2-inch diesel line is isolated from the control system for the overall operation of the Oooguruk facilities for monitoring purposes. Therefore, if the facility’s control room and controllers are not used to monitor the 2-inch diesel line, the § 195.446 requirements do not apply to the operation of this line.
On the other hand, if the facility’s control room and controllers are used to monitor the 2-inch diesel line, no matter how infrequently the line is used, Caelus must comply with the requirements of § 195.446.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
John A. Gale
Director, Office of Standards
|§ 195.446||Control room management|