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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-01-0101 ([Prodica LLC] [Mr. Steven A. Davey])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Prodica LLC

Individual Name: Mr. Steven A. Davey

Location State: WA Country: US

View the Interpretation Document

Response text:


Mr. Steven A. Davey
Central Support Department
Prodica LLC (Agrium US Inc.)
227515 E. Bowles Road
Kennewick, WA 99337-0618

Dear Mr. Davey:

Thank you for your letter of September 1, 2000 (ref. E: 00-111) which requests an interpretation of the jurisdictional status of two anhydrous ammonia pipelines under 49 CFR Part 195.1(b).

You state that both hazardous liquid pipelines are "less than 1 mile in length (measured fence to fence), transport anhydrous ammonia in the liquid phase, and are low stress" and that "neither pipeline crosses navigable waterways or are located offshore." You allege that the pipelines are not jurisdictional per 195.1(b)(3)(iii).

The hazardous Liquid pipeline regulations, 49 CFR Part 195, apply to all pipeline facilites used in the transportation of petroleum, petroleum products, and anhydrous ammonia except as specified in § 1951(b) as follows:

(b) This part does not apply to-

(1) Transportation of a hazardous liquid that is transported in a gaseous state;
(2) Transportation of a hazardous liquid through a pipeline by gravity;
(3) Transportation through any of the following low-stress pipelines:

(i) An onshore pipeline or pipeline segment that;

(A) Does not transport a HVL [highly volatile liquid];
(B) Is located in a rural area; and
(C) Is located outside a waterway currently used for commercial navigation

(ii) A pipeline subject to safety regulations of the U.S Coast Guard; or
(iii) A pipeline that serves refining, manufacturing, or truck, rail or vessel terminal facilities, if the pipeline is less than I mile long (measured outside facility grounds) and does not cross an offshore area or a waterway currently used for commercial navigation.

Under § 195 1(b)(3)(iii) a low-stress pipeline that serves manufacturing facilities and is less than one mile long and does not cross a waterway is not subject to the pipeline safety regulations, even if it transports an HVL, such as anhydrous ammonia.

Therefore, based on the representations made in your letter of September 1 2000, the Federal pipeline safety regulations do not apply to the two hazardous liquid pipelines operated by Prodica L.L.C (Agrium US Inc.).

If you require further information on this issue, please contact me at (202) 366-4565.


Richard D. Huriaux, P.E.
Regulations Manager
Office of Pipeline Safety

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?