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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-04-0107 ([BP America Production Company] [Mr. George Williamson])

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

Interpretation Response Details

Response Publish Date:

Company Name: BP America Production Company

Individual Name: Mr. George Williamson

Location State: TX Country: US

View the Interpretation Document

Response text:


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

April 20, 2004

Mr. George Williamson
Onshore United States Business Unit
DOT Regulatory Compliance Manager
BP America Production Company
501 Westlake Park Blvd.
Office 2.366
Houston, TX 77079

Dear Mr. Williamson:

This is in response to your letter of March 31, 2004, in which you request an interpretation of the gas pipeline safety regulations at 49 CFR 195.1, Applicability. You ask whether a 2 to 3.5 inch diameter pipeline transporting petroleum from a production facility to a refinery in a rural area is a gathering line that is excepted by § 195.1(b)(4) from compliance with the pipeline safety regulations of Part 195.

Section 195.1(b)(4) specifies that Part 195 does not apply to "transportation of petroleum in onshore gathering lines in rural areas..." Gathering line is defined in § 195.2 as a pipeline less than 8 5/8 inches outside diameter that transports petroleum from a production facility. The same section defines Production facility as piping used in the production, extraction, recovery, lifting, stabilization, separation, or treating of petroleum.

Based on your representation that the pipeline in a rural area near Evanston, Wyoming, is less than 8 5/8 inches outside diameter and transports petroleum directly from a production facility, it appears that the pipeline meets the requirements of § 195.1(b)(4). Therefore, it is not subject to safety regulation under Part 195.

However, a final determination of the regulatory status of your pipeline can only be made pursuant to inspection by the Office of Pipeline Safety. If you have questions about inspection procedures, please contact the Office of Pipeline Safety's Western Region office in Lakewood, CO at 303-231-5701.

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?