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Demarcation pipeline and plant per DOT

Demarcation pipeline and plant per DOT

Demarcation pipeline and plant per DOT

I've reviewed all the DOT papers and guidance and interpertations on the demarcation where a DOT pipeline starts and where the OSHA/EPA regulated plant ends.

Heres what I get.  We have a seperate overpressure protection system with a pilot operated valve that isolates the pipeline just upstream from the pig launcher.  This is what we call the demarcation point, downstream of the valve built B31.8 maintained operated under DOT 195.  Upstream build, inspected and maintained under B31.3 and OSHA/PSM & EPA/RMP

The local state DOT people say no, the pumps way back inside the plant create the pressure and therefore are covered under DOT 195 and all piping, maintenance and operations including OQ and DOT certified pump manufactures (OQ qualified) must be in place.

What say you?

RE: Demarcation pipeline and plant per DOT

First problem is you have a pipeline built to Gas Code B31.8 (and just maybe perhaps CFR 49-192 ?) and you are apparently operating as a liquid line under CFR 49-195.  How do you do that?  

Now I don't know which code or which regulation to look at, but both of them include the motive power, compressors or pumps respectively.

******************** GAS ***************************

CFR 49 192.3 Definitions

Pipeline means all parts of those
physical facilities through which gas
moves in transportation, including
pipe, valves, and other appurtenance
attached to pipe, compressor units, metering
stations, regulator stations, delivery
stations, holders, and fabricated

********************** 195 *******************
CFR 49 Part 195.2 Definitions

>>>You're not "In-plant assuming that a pump and iso valve controls pressure", which is pretty hard to argue that they don't<<<<

In-plant piping system means piping
that is located on the grounds of a
plant and used to transfer hazardous
liquid or carbon dioxide between plant
facilities or between plant facilities
and a pipeline or other mode of transportation,
not including any device and
associated piping that are necessary to
control pressure
in the pipeline under
§ 195.406(b).

Pipeline or pipeline system means all
parts of a pipeline facility through
which a hazardous liquid or carbon dioxide
moves in transportation, including,
but not limited to, line pipe,
valves, and other appurtenances connected
to line pipe, [b]pumping units[b], fabricated
assemblies associated with
pumping units, metering and delivery
stations and fabricated assemblies
therein, and breakout tanks.
Pipeline facility means new and existing
pipe, rights-of-way and any equipment,
facility, or building used in the
transportation of hazardous liquids or
carbon dioxide.
When I worked a NNG and Enron, we designed all Gas components inside and outside compressor stations for CR49/192 & B31.8.  When I worked for Gulf Interstate Engineering, Bechtel, Pipeline Technologists, Botas, Aramco, all compressor stations were B31.8 and all pump stations for all facilities & for all clients were B31.4 (& CFR 49/192-195 when in USA).  

Actually I never understood why some refineries and chem plant operators think B31.3 applies to pipelines.  B31.4-2002 has a Scope Diagram and all "pump stations" are shown as included.

"If everything seems under control, you're just not moving fast enough."
- Mario Andretti- When asked about transient hydraulics


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