Interpretation Response #PI-95-038 ([Hoechst Celanese Corporation] [Richard Buckley-Correa])

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

Interpretation Response Details

Response Publish Date: 09/12/1995

Company Name: Hoechst Celanese Corporation

Individual Name: Richard Buckley-Correa

Location State: TX Country: US

View the Interpretation Document

Response text:

September 12, 1995

Mr. Richard Buckley-Correa

Hoechst Celanese Corporation

1601 West LBJ Freeway

P.O. Box 819005

Dallas, TX 75381-9005

Dear Mr. Buckley-Correa:

This responds to your letter of July 19, 1995, to Cesar DeLeon, Deputy Associate Administrator, Office of Pipeline Safety, regarding the hazardous liquid pipeline safety regulations (49 CFR Part 195). You want to know if we consider the definition of "petroleum product" to include liquids besides those that are produced by separating crude petroleum.

In Part 195, "petroleum product" means flammable, toxic, or corrosive products obtained from distilling and processing of crude oil, unfinished oils, natural gas liquids, blend stocks and other miscellaneous hydrocarbon compounds (§195.2). Under this definition, any flammable, toxic, or corrosive liquid that is produced by distilling or processing hydrocarbon compounds is a petroleum product and, thus, a hazardous liquid under Part 195. Petroleum products are not limited, as you suggest, to refinery products produced by crude oil distillation or cracking. They also include petrochemicals produced from other hydrocarbons, including natural gas, natural gas liquids, coal, coal tar, or charcoal.

You also asked if we consider ethylene glycol and formic acid to be hazardous liquids under Part 195. Since these liquids have a hydrocarbon base and are, respectively, flammable and corrosive products under the definitions in §195.2, we consider them to be petroleum products and hazardous liquids under Part 195.

I hope you find this information helpful. Please let me know if you have any further questions about the hazardous liquid pipeline safety regulations.

Sincerely,

Richard D. Huriaux, P.E.

Director for Technology and Regulations

Office of Pipeline Safety

Regulation Sections