• Intra-facility gathering lines may fall under the jurisdiction of the EPA and DOT.

Intra-facility gathering lines (i.e., gathering lines found within the confines of a non-transportation-related facility) may be under the jurisdiction of both the Environmental Protection Agency (EPA) and the Department of Transportation (DOT). However, certain DOT requirements for pipelines are considered to be similar in scope to Part 112 regulations. Therefore, intra-facility gathering lines that are subject to DOT regulatory requirements at Part 192 (Transportation of Natural and Other Gas by Pipeline) or Part 195 (Transportation of Hazardous Liquids by Pipeline) are exempt from Part 112 under 112.1(d)(11).

If intra-facility gathering lines are not subject to DOT regulatory requirements (i.e., gathering lines that by statute are subject to DOT jurisdiction, yet are not subject to the DOT regulations), they remain subject to Part 112. Other equipment and piping at an oil production facility (such as flowlines) remain subject to Part 112 requirements. EPA considers intra-facility gathering lines to be subject to EPA’s jurisdiction if they are located within the boundaries of an otherwise regulated Part-112-covered facility.

The exemption requires owners or operators of a facility to identify and mark as “exempt” the location of exempt piping on the facility diagram. This requirement will assist both facility and EPA personnel in defining the boundaries of EPA and DOT jurisdiction and provide response personnel with information used to identify hazards during a spill response activity. More information about facility diagram requirements is provided at Written plans.