{"operation":"document","citation":"05-0066","title":"Scana Power for Living — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-08-03","effective_on":null,"summary":"05-0066 response to Scana Power for Living concerning 172.800.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0066.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0066.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0066","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050066.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nAUG 3 2005\n400 Seventh Street, S.W\nNashington, D.C. 2059\nPipeline and\nAdministration\nHazardous Materials Safety\nMike E. Moore, P.G.\nReference No. 05-0066\n6248 Bush River Road\nScana Power for Living\nColumbia, SC 29212-0934\nDear Mr. Moore:\nThis is in response to your e-mails concerning whether or not a plant's receiving facility is\nCFR Parts 171-180). You state the plant's employees assist carriers with off-loading bulk\nrequired to develop a security plan under the Hazardous Materials Regulations (HMR; 49\npackages of hazardous material, as well as other related tasks.\nSection 172.800(b) requires each person who offers for transportation or transports in\ncommerce one of the hazardous materials listed in §§ 172.800(b)(1) through 172.800(b)(7) to\ndevelop and implement a security plan. Under the HMR, facilities that receive hazardous\nmaterials are not required to have security plans.\nI hope this information is helpful.\nSincerely\nMatte 7. mittel\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n172.800\n050066\n\n<<>>\n\nPage 1 of 1\nEdmonson, Eileen \nFrom: MOORE, MICHAEL E [MMOORE@scana.com]\nEdmonson\nSent: Tuesday, March 22, 2005 4:14 PM\nEdmonson, Eileen \n3172. 800\nSubject: DOT Security Plan Triggers\ncunty Plan\n15-0066\nrequiring the receiving facility to create and implement a Security Plan. Any amplifying information, citations, etc. would be\nThis is to follow up on our phone conversation regarding the following scenario and the implications for triggering or\nthat are required for plant operations. Typically off loading various hose hook ups are made by the delivering carriers\nScenario: A Facility receives Fuel Oil, Sulfuric Acid, Anhydrous Ammonia, and various other Bulk shipments of Haz Mat\ndriver. In most cases facility operational personnel will also be engaged during the delivery to operate facility valving,\nfunction to respond if an off normal event occurred. As such, aiding in the delivery would make these facility employees\npumps, or other process controls in the vicinity of the unloading vehicle, or even signing for the delivery. They would also\ncreate a \"Security Plan for the Site\"? Does it matter if the Haz Mat delivered is being transported and delivered under a\nThe question is whether any of the activities described where a facility receives Haz Mat is a trigger for the Facility to\nSecurity Plan?\nSCANA\nPOWER FOR LIVING\n6248 Bush River Road\nMike E. Moore, P.G.\nColumbia, SC 29212-0934\n803-217-9302 office\n803-933-7220 fax\n803-331-4463 mobile\n\n03/22/2005","truncated":false,"body_characters":2641}