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Interpretation Response #PI-92-043 ([Memo: Internal])

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

Interpretation Response Details

Response Publish Date:

Company Name: Memo: Internal

Individual Name:

Country: US

View the Interpretation Document

Response text:

August 24, 1992

INFORMATION: Part 195 Jurisdiction

Cesar De Leon

Director, Regulatory Programs, DPS-10

Ed Ondak

Director, Western Region, DPS-28

Your memo of June 16, 1992, asks if Part 195 applies to two pipelines. The first one, an 8-inch collection line that operates at less than 20% SMYS, transports stove oil from a Unocal facility in Portland to a nearby Santa Fe pipeline, which runs between Portland and Eugene. The second, a 12-inch delivery line that operates at less than 20% SMYS, transports gasoline from an Olympic pipeline, which runs between Washington State and Portland, to a Unocal facility in Portland.

Part 195 applies to pipelines used in the transportation of hazardous liquids. However, ?195.1(b)(3) exempts transportation of a hazardous liquid through pipelines that operate at a stress level of 20 percent or less of SMYS. Because Part 195 applies to entire pipeline systems, in applying this exemption, we consider an entire pipeline system that operates at 20 percent or less of SMYS is exempt.

Neither pipeline you asked about is a unique system. Each one is merely a part of a larger system, serving either to introduce products into the system or take products from it. Therefore, each pipeline is subject to Part 195. Ownership of the pipelines is not a relevant jurisdictional consideration.

Regulation Sections