Plug this hole in regs

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Wow, something good came of the Parachute spill. There are actual calls for regulation coming from the Sentinel! Amazing.

I had proposed to Dennis Webb that the Colorado Dept. of Labor had jurisdiction over the tanks and interconnecting pipelines by following the lead of their jurisdiction over Boilers and Pressure Vessels. The associated pipelines are usually under the rules of the pressure vessels when they are connected. This led to:
Mr. Webb related, in follow-up, they had informed him that their jurisdiction was to “commercial” handlers of petroleum products. Buried in Sect. 3-1 (b) (5 )or (11). liquid petroleum gases and separation could be a disclaimer of tanks under jurisdiction or by deferring the tanks to the U.S. Dept. of Transportation below (see highlight of on liquid pipelines) as part of their system.

The Colorado Pipeline Association (CoPA) is comprised of pipeline operators in Colorado that are dedicated to promoting pipeline safety by providing information for excavators, state residents, businesses, emergency responders and public officials.

The Colorado Public Utility Commission’s (PUC) Pipeline Safety Group inspects, regulates and enforces intrastate gas pipeline safety requirements. The Office of Pipeline Safety (OPS), within the U. S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) inspects, regulates and enforces interstate gas pipeline safety requirements and both interstate and intrastate liquid pipeline safety requirements.

I disagree with CDoL, as, if the vessels and a connecting lines are not under their Div. of Oil and Public Safety, it is under their Boiler and Pressure Vessel Section with pressure vessels and connecting lines. However, if each State agency disclaimers are valid or they refuse accepting jurisdiction, then the U.S.D.O.T. would have jurisdiction by that State refusal to accept code enforcement by either PUC or CDoL as local regulatory agencies. If U.S.D.O.T. has a jurisdictional interest, then they too can fine for failures that result in spills and they have rules and safety regulations for construction, maintenance, and operation of these systems. Now CDPHE, has Hazardous Waste Clean-up, either U.S.D.O.T. or a State agency should have safety requirements for the systems, and if these are not as should be, they should also have penalty for breaches. CDPHE should fine to recover cost of supervising clean-up, and, punitive if cause is relative to violations of other agency requirements of safety.

In this post I would address that I do not believe Williams has a valid claim that the regulations do not apply to its’ line crossing the creek. There are most likely gathering tank/pipe and pump(s) in the plant. This is because it is necessary to keep the volatiles in a liquid stage after cold separation and to provide head to the next storage tanks. Although there are special requirements for creek crossings, it does not exclude that transport line from plant to storage tanks from jurisdiction. Wherein, storage away from plant can be a safety feature, the pipelines are all still transport lines subject to the requirements of pipeline safety. This appears to me as an attempt to “loophole” a transferring pipeline and I would say, if this line sent the liquids to tanks in Rifle or Rangeley or Grand Junction it would be clearly regulated by PHMSA and the only difference would be the pump size in the plant and the line length to the tanks.

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