PHMSA Response Letter

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November 9, 1995

Mr. Chris J. Harvey
Administrator, Gas Pipeline Safety
Alabama Public Service Commission
P.O. Box 991
Montgomery, Alabama 36101-0991

Dear Mr. Harvey:

You requested a determination of jurisdiction of a 4.5 inch diesel pipeline used to assist production on an Exxon offshore facility in Mobile Bay Block 62. This question was raised following an inspection of this facility and Exxon's subsequent contention that the 4.5 inch line in question was exempt from the requirements of 49 CFR 195 because it was a gathering line.

Under 49 CFR 195.2, a gathering line means "a pipeline 8 inches or less in nominal diameter that transports petroleum from a production facility." Because the pipeline in question transports diesel fuel from an onshore facility to the offshore production facilities, it cannot be classified as a gathering line.

Therefore, it is jurisdictional to the requirements of 49 CFR 195. If you have any further questions, please contact the Office of Pipeline Safety, Southern Region, at (404) 347-2632.

Sincerely,

Cesar DeLeon
Deputy Associate Administrator
for Pipeline Safety