Interpretation Response #PI-11-0010 ([Gallagher Evelius & Jones LLP] [Ms. Alison S. F. Lambert])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gallagher Evelius & Jones LLP
Individual Name: Ms. Alison S. F. Lambert
Location State: MD Country: US
View the Interpretation Document
Response text:
Ms. Alison S. F. Lambert
Gallagher Evelius & Jones LLP
Attorneys At Law
218 North Charles Street
Suite 400
Baltimore, MD 21201
Dear Ms. Lambert:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated May 26, 2011, you asked for guidance regarding the reporting requirements in the Federal pipeline safety regulations ( 49 CFR Parts 190-199). You stated that you represent a pipeline operator who currently transports a petroleum-based product by pipeline, but that the company is considering changing the type of petroleum-based product it transports. You would like guidance on the applicable reporting requirements for product change that are administered by PHMSA.
With certain exceptions, the reporting requirements in Subpart B of Part 195 apply to the transportation of petroleum or petroleum products by pipeline. [1] That includes "crude oil, condensate, natural gasoline, natural gas liquids, and liquefied natural petroleum gas," as well as any "flammable, toxic, or corrosive products obtained from the distilling and processing of crude oil, unfinished oils, natural gas liquids, blend stocks and other miscellaneous hydrocarbon compounds." [2]
A pipeline operator can change the kind of petroleum or petroleum product transported without affecting its obligations under Subpart B of Part 195. In other words, the reporting requirements for pipeline facilities used in the transportation of hazardous liquids or carbon dioxide remain the same as long as the pipeline operator continues to transport any form of hazardous liquids as defined in § 195.2.
I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046.
Sincerely
John A. Gale,
Director, Office of Standards and Rulemaking
The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.