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In This Issue

  1. Advisory bulletin: Self-Assessment of Pipeline Operator Public Education Programs
  2. Need to update your Public Awareness Program?
  3. Corrosion Threat to Newly Constructed Pipelines: Advisory Bulletin (ADB-03-06)
  4. Gas Pipeline Advisory Bulletin: Start of Baseline Assessment
  5. Integrity Management Plan Up-to-Date?
  6. Pipeline Surge Tanks are DOT Regulated
  7. Need A HAZMAT Security Plan?
  8. Passage of Internal Inspection Devices – Request for information
  9. O&M Manual Up-To-Date?
  10. Gas and Hazardous Liquid Gathering Lines: Notice of Public Meeting and Request for Comments
  11. RCP Services Spotlight – Pipeline Acquisition Due Diligence & Program Support

Pipeline Surge Tanks are DOT Regulated

Just in case you weren’t sure, in 49 CFR 195.2 the Office of Pipeline Safety makes it clear that any “tank used to relieve surges in a hazardous liquid pipeline system” is considered a breakout tank and therefore falls under DOT jurisdiction. This is the case even if EPA also regulates the tank, such as at a refinery. So, if a regulated pipeline uses your tank for operational pressure relief surges, you have a breakout tank.
In addition to the applicable general pipeline safety requirements, breakout tank requirements include

  • Design and construction (195.132)
  • Repair, alteration and reconstruction (195.205)
  • Impoundment, protection against entry, normal/emergency venting or pressure/vacuum relief (195.264)
  • Pressure testing (195.307)
  • Protection against ignitions and safe access/egress involving floating roofs (195.405)
  • Overpressure safety devices and overfill protection systems (195.428)
  • Inspection (195.432)

Not sure if your plant tanks are regulated? RCP can do a jurisdictional determination and help ensure that your breakout tanks are in full compliance with DOT requirements as needed.