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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-04-0100 ([Marathon Ashland Pipe Line LLC] [Mr. Tad Schell, P.E.])

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 Schell, P.E.

Location State: OH Country: US

View the Interpretation Document

Response text:


U.S. Department of Transportation
Research and Special Programs Administration
400 Seventh Street, S.W.
Washington, D.C. 20590

January 22, 2004

Mr. Tad Schell, P.E.
Senior Regulatory Compliance Coordinator
Marathon Ashland Pipe Line LLC
Environmental, Safety & Regulatory Compliance
539 South Main Street
Findlay, OH 45840-3205

Dear Mr. Schell:

This is in response to your e-mail of November 21, 2003, in which you request an interpretation of 49 CFR 195.1(b)(3)(iii) as it applies to low-stress, highly volatile liquid (HVL) pipelines. Specifically, the question arises for a proposed Marathon Ashland Pipe Line LLC (MAPL) pipeline transporting HVL less than one mile between the MAPL Texas City refinery and a Dow Chemical plant. MAPL states that the pipeline is low stress and does not cross any waterway used for commercial navigation.

Section 195.1(b)(3)(iii) of the hazardous liquid pipeline safety regulations addresses one of nine exceptions to the applicability of Part 195 to hazardous liquid pipelines. Section (b)(3) states that this part does not apply to--

(1) Transportation through any of the following low-stress pipelines:

(I) An onshore pipeline or pipeline segment that--

(A) Does not transport HVL;
(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 regulation of the U.S. Coast Guard; OR
(iii) A pipeline that services refining, manufacturing, or truck, rail, or vessel terminal facilities, if the pipeline is less than 1 mile long (measured outside facility grounds) and does not cross an offshore area or a waterway currently used for commercial navigation.

To be exempt from regulation under Part 195, a hazardous liquid pipeline must meet only one of these three criteria. Based on MAPL's description of the proposed pipeline, it would be exempt from regulation under § 195.1(b)(3)(iii).
If you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.


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

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?