# Marathon Oil Company — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-74-002
- **title:** Marathon Oil Company — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1974-01-01
- **effective on:** Not available
- **summary:** PI-74-002 response to Marathon Oil Company concerning 195.8.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-002
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/PI74002.pdf
**body:**

<<<PAGE 1>>>

January 1, 1974
Mr. Larry D. Wheaton
Marathon Oil Company
539 S. Main Street
Findlay, OH 45840
Dear Mr. Wheaton:
This refers to your letter of December 7, 1973, furnishing this
Office additional information concerning "slug" used in your
Maraflood TM Process.
Based on the information provided in your letter, the Office of
Pipeline Safety (OPS) has determined that the subject slug would
not be classified as a hazardous material, petroleum, or
petroleum product and therefore its pipeline transportation would
not be subject to the requirements of 49 CFR, Part 195,
Transportation of Liquids by Pipeline.
Your letter also requested clarification in two additional areas.
Question
"Does section 195.8 concerning notification of the use of plastic
pipe apply if the material transported is not a hazardous
material?"
Answer
If the material being transported by pipeline is not classified
as a hazardous material, then it would not be required to comply
with 49 CFR, Part 195.
Question
"If so" (answer to preceding question) "does it" (Section 195.8)
"apply if the material is not being transported by a common
carrier?"
Answer
If a material is classified as a hazardous material, petroleum,
or petroleum product transported by pipeline, the carrier would
have to comply with Part 195 if it is determined that the carrier
is subject to Federal safety regulatory jurisdiction in
accordance with the following.
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<<<PAGE 2>>>

The liquid pipeline safety regulations are issued by
the OPS under the authority of Title 18, United States
Code, Sections 831-835. This safety authority is
applicable to all common, private, and contract
pipeline carriers in interstate and foreign commerce,
who transport petroleum, petroleum products, and other
liquid hazardous materials. Title 18, U.S.C., Section
834 provides that the regulations issued by the
Department under this section are ". . . binding upon
all carriers engaged in interstate or foreign commerce
which transport explosives and other dangerous articles
by land, and upon all shippers making shipments of
explosives and other dangerous articles via any carrier
engaged in interstate and foreign commerce by land or
water" (emphasis added). Therefore, OPS regulations
apply to carriers engaged in interstate operations, and
to all pipelines operated by such carriers, regardless
of whether the particular pipeline is interstate or
intrastate.
We appreciate your efforts in supplying the requested information
and if we can be of any further help, please contact this Office.
Sincerely,
Joseph C. Caldwell
Director
Office of Pipeline Safety
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