Interpretation Response #PI-23-0004
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. Pat Westrick
Director of Integrity Management Services
2627 Redwing Road
Fort Collins, CO 80526
Dear Mr. Westrick:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated October 5, 2022, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 195 with respect to application of certain exceptions under § 195.1(b) to your pipeline facility.
You stated you are requesting an interpretation on behalf of your client Sasol Chemicals USA LLC ("Sasol") located in Westlake, Louisiana. You stated currently the facility operates six pipelines that travel from the Sasol plant through the adjacent Phillips 66 refinery to a Phillips 66 vessel terminal facility port located on the Calcasieu River. You stated all six of the pipelines are low stress pipelines operating below 20 percent of the specified minimum yield strength of the pipe. You stated that all six pipelines cross the Old Spanish Trail Road for 70 feet between the Sasol facility and the Phillips 66 refinery. You stated the pipelines then travel from 1.68 to 1.77 miles (depending on the pipeline) through the Phillips 66 refinery with numerous valves located within the refinery. You stated when required per Sasol and Phillips 66 operating procedures, Phillips 66 personnel are authorized to operate the Sasol pipeline valves within the refinery.
You stated after the pipelines leave the Phillips 66 refinery, they travel south for 0.32 miles before entering the Phillips 66 terminal where they travel another 0.18 miles before they become regulated by the U.S. Coast Guard for the remaining 0.26 to 0.60 miles. You noted the pipelines travel less than one mile to the terminal after leaving the Phillips 66 refinery and do not cross a commercially navigable waterway. You provided a table and a map as a summary.
You asked PHMSA if the pipelines qualify for either the exception for low-stress pipelines serving a vessel terminal if the pipeline is less than one mile long and does not cross a waterway used for commercial navigation, as described in § 195.1(b)(3)(ii), or for transportation of hazardous liquid or carbon dioxide through refining facilities as described in § 195.1(b)(8).
On January 27, 2023, PHMSA requested additional information, and you responded to PHMSA on March 3, 2023. One of PHMSA's questions was whether Sasol's products are processed and/or refined at the Phillips 66 refinery before entering the marine terminal. You responded stating that the refinery does not process any material transported by these pipelines, and that the only pipelines having any interaction with the Phillips 66 refinery are the heavy paraffin #24 and light paraffin #8 pipelines that connect to tanks within the Phillips 66 refinery, where Sasol products may be stored for re-origination on the same pipelines.
Based on the information you have provided, the Sasol pipelines from the Sasol facility to the marine terminal or the U.S. Coast Guard regulation line are longer than the one-mile limit for the § 195.1(b)(3)(ii) exception. In addition, the § 195.1(b)(8) exception does not apply because the pipelines only traverse the Philips 66 refinery, the pipelines do not transport hazardous liquid or carbon dioxide through the refining facilities at the Phillips 66 refinery. Therefore, the Sasol pipelines are regulated pipelines under the § 195.1(a) requirements.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
John A. Gale
Director, Office of Standards
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