Interpretation Response #PI-78-021 ([Union Oil Company of California] [Mr. Calvin F. Broussard])

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

Interpretation Response Details

Response Publish Date: 07/17/1978

Company Name: Union Oil Company of California

Individual Name: Mr. Calvin F. Broussard

Location State: LA Country: US

View the Interpretation Document

Response text:

Mr. Calvin F. Broussard

Production Technician

Union Oil Company of California

P.O. Box 51388, O.C.S.

Lafayette, Louisiana 70505

Dear Mr. Broussard;

We apologize for the delay in answering your letter of May 5, 1978, concerning the jurisdictional demarcation under the Memorandum of Understanding (MOU) between the Department of
Transportation (DOT) and the Department of the Interior (DOI) regarding offshore pipelines. Under the MOU, DOT is responsible for "pipelines extending to the shore from the outlet flange" at certain offshore facilities. DOI is responsible for "pipelines extending upstream from the outlet flange."

We concur with your interpretation that jurisdictional demarcation occurs "at the last flange on a platform before or upstream of the departing pipeline riser." We also concur that as shown on your typical gas production schematic, the last flange is within the area of DOT responsibility.

Sincerely,

Cesar DeLeon

Associate Director for

Pipeline Safety Regulation

Materials Transportation Bureau

Regulation Sections