PHMSA/DOT Pipeline Permitting
PHMSA/DOT Pipeline Permitting
(OP)
I have a client looking at expanding an existing terminal (non-DOT) with pipeline in/out. I believe that, given the fact that it will be a DOT-regulated terminal once they start piping into and out of it, any new work needs to be DOT-compliant and would require full design and drawings. I ask as they basically said they will have their contractor handle all the in-terminal piping and electrical, and only need drawings for the pipeline. I'm concerned they may get bitten by this (from a compliance standpoint, assuming the resulting construction itself is fine), but I can't find anything discussing if that is the case.
Any feedback on essentially what regulatory requirements are for "minimum design documentation" required?
Any feedback on essentially what regulatory requirements are for "minimum design documentation" required?





RE: PHMSA/DOT Pipeline Permitting
see: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=ca3d88e943c9b3619f96ac3d22f1c200&c=ecfr&tpl=/ecfrbrowse/Title49/49cfrv3_02.tpl
see attached doc for further assistance. good luck!
-pmover
RE: PHMSA/DOT Pipeline Permitting
Basically, do they need drawings or specs per code (or a PE to sign/seal) or as long as they have "a design" that meets CFR 195, they're good. It might be on a napkin or in the contractors head, but it meets the physical characteristics of the design performance requirements...
RE: PHMSA/DOT Pipeline Permitting
What would you be doing, if you knew that you could not fail?
RE: PHMSA/DOT Pipeline Permitting
One nasty little twist in this regulation is that if you add to a system without proper controls, the entire system becomes jurisdictional. For example, one of my clients had a 20 mile 6-inch gas line that was in farm country and there wasn't enough population anywhere along its length to trigger 195. Then a land owner subdivided his farm and built a hundred houses within 500 ft of the pipe over a couple of mile section. That brought in the whole 20 mile section and we were faced with digging up a bunch of pipe to re-run x-rays, new static test, etc since none of those records had survived commissioning in the 1980s. What we ended up doing was putting ESD valves at the property line on both ends of the property and only treating the 2 miles as jurisdictional. It was still an expensive pain with no real public benefit, but it was 1/10 the cost of doing the same thing over 20 miles.
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
RE: PHMSA/DOT Pipeline Permitting
Back to Breakout Tanks,
195 Definitions,
Breakout tank means a tank used to (a) relieve surges in a hazardous liquid pipeline system or (b) receive and store hazardous liquid transported by a pipeline for reinjection and continued transportation by pipeline.
Not covering tanks used at terminals, transporting from pipeline mode to a non-pipeline mode, trucks, railroad, etc. are not included. See 195.1 b,8(ii)
Breakout tanks section 8, C.
http://www.gpo.gov/fdsys/pkg/CFR-2006-title49-vol3/xml/CFR-2006-title49-vol3-sec195-1.xml
195.132 Design and construction of aboveground breakout tanks.
http://www.eng-tips.com/viewthread.cfm?qid=322248
195.264 Impoundment, protection against entry, normal/emergency venting or pressure/vacuum relief for aboveground breakout tanks.
http://www.gpo.gov/fdsys/pkg/CFR-2006-title49-vol3/xml/CFR-2006-title49-vol3-part195-subpartD.xml
Terminals are not covered by 195, except for any "breakout" tanks and, of course, those portions of a covered "pipeline" that might be located therein.
What would you be doing, if you knew that you could not fail?
RE: PHMSA/DOT Pipeline Permitting
The key element was the ESD valves (I wanted to use trunnion ball valves with a solenoid on the body bleed, but was overruled and two actuated trunnion ball valves with an automated vent between them were used). The DOT found our technique to be a best practice.
The part about the GOM didn't stick in my mind since this project was at least 3 states away from the nearest ocean.
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
RE: PHMSA/DOT Pipeline Permitting
What would you be doing, if you knew that you could not fail?
RE: PHMSA/DOT Pipeline Permitting
So my take is... there is no formal review prior to construction (except local or state jurisdiction for building, fire, stormwater, etc). The system (breakout tanks, terminal piping, pipeline, etc) must be built according to CFR 195, and that includes some design requirements. It must also be rigorously tested and MTRs maintained. And at the end DOT/PHMSA/OPS will request documentation of the system meeting the CFR - which could be drawings and specs or hand-calculations on a notepad, as well as test records, etc. Lastly, the OPS will ask for pipeline route for the NPMS system.
So they can have the contractor field route pipe, based on rough calculations to ensure it meets CFR for pressure. And then get documentation at the end to pretty it up for PHSMA. Sounds risky to me, but I guess if not paying for engineering is attractive at the outset, it's worth the risk!
RE: PHMSA/DOT Pipeline Permitting
Station tanks that store crude and products for use within a refinery, within a power plant (for fuel storage), for loading trucks, or rail tank cars, farm tractors, airports or airplanes, are not breakout tanks and do not fall within 195, but certainly would fall under NFPA and local fire regulations, possibly state regulation of one sort or another, as well as EPA vapor emission regulations. As long as crudes, or products contained in a tank cannot be, or will not be (?) used for further pipeline transport, those tanks are station tanks ie. NOT part 195 coverage.
As far as I know, DOT does not inspect first, or during construction. The owner/operator will be required to certify that everything meets DOT/CFR requirements in the permit to operate process. This is as far as I know, which may not be very far, since, BE WARNED, I have not worked stateside since 1991. We should wait to see if anybody else can add something to that.
What would you be doing, if you knew that you could not fail?
RE: PHMSA/DOT Pipeline Permitting
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
RE: PHMSA/DOT Pipeline Permitting
What would you be doing, if you knew that you could not fail?