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Interpretation Response #PI-01-0103 ([Marathon Ashland Pipe Line, LLC] [Mr. Tad A. Schell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Marathon Ashland Pipe Line, LLC

Individual Name: Mr. Tad A. Schell

Location State: OH Country: US

View the Interpretation Document

Response text:


Mr. Tad A. Schell
Regulatory Compliance Officer
Marathon Ashland Pipe Line, LLC
539 South Main Street
Findlay, OH 45840-3295

Dear Mr. Schell:

I am responding to your letter concerning an LPG storage tank on the grounds of a refinery. You requested our opinion on whether the tank is subject to 49 CFR Part 195.

According to your letter, the refinery produces LPG from crude oil and stores it in the tank for use at the refinery or sale to marketers. The refinery also transfers LPG back and forth between the tank and a remote storage cavern via regulated pipelines.

As provided in § 195.1(b)(7), Part 195 does not apply to "transportation of a hazardous liquid or carbon dioxide through onshore production (including flow lines), refining, or manufacturing facilities, or storage or in-plant piping systems associated with such facilities." Thus, storage associated with refining facilities is not covered by Part 195. It follows that because the LPG tank in question is associated with refining operations, Part 195 does not apply to the tank.

I hope this information meets your needs. If you would like further assistance, please call Mr. Lucian Furrow, of my staff, at (202) 366-4559.


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

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?