{"operation":"document","citation":"PI-78-021","title":"Union Oil Company of California — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-07-17","effective_on":null,"summary":"PI-78-021 response to Union Oil Company of California concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-021.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-021.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-021","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78021.pdf","body":"<<<PAGE 1>>>\n\nJuly 17, 1978\nMr. Calvin F. Broussard\nProduction Technician\nUnion Oil Company of California\nP.O. Box 51388, O.C.S.\nLafayette, Louisiana 70505\nDear Mr. Broussard;\nWe apologize for the delay in answering your letter of May 5, 1978, concerning the jurisdictional\ndemarcation under the Memorandum of Understanding (MOU) between the Department of\nTransportation (DOT) and the Department of the Interior (DOI) regarding offshore pipelines.\nUnder the MOU, DOT is responsible for \"pipelines extending to the shore from the outlet flange\"\nat certain offshore facilities. DOI is responsible for \"pipelines extending upstream from the outlet\nflange.\"\nWe concur with your interpretation that jurisdictional demarcation occurs \"at the last flange on a\nplatform before or upstream of the departing pipeline riser.\" We also concur that as shown on\nyour typical gas production schematic, the last flange is within the area of DOT responsibility.\nSincerely,\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\ndal\\192.1-a\\1\\78-07-17\n1\n\n<<<PAGE 2>>>\n\nMay 5, 1978\nOffice of Pipeline Safety Operation\n2100 2nd Street\nS.W. Washington, D.C. 20590\nAttention: Mr. Cesar DeLeon, Acting\nDirector\nGentlemen: Re: Request for Interpretation of Memorandum of\nUnderstanding Between the Department of\nTransportation and the Department of the\nInterior Regarding Offshore Pipelines.\n_\nThe Memorandum of Understanding Between the Department of Transportation and the Interior\nRegarding Offshore Pipelines establishes the different areas of jurisdiction of the two Departments\nbut the exact point of jurisdictional change is not clear. This was discussed by telephone with Mr.\nFrank Fulton with the Office of Pipeline Safety Operation on March 15, 1978. He suggested that\na formal letter be written with a typical schematic indicating this point of jurisdictional change.\nThe attached schematic illustrates the major production equipment and flow pattern on a typical\ngas production platform. Jurisdictional change is indicated at the last flange on a platform before\nor upstream of the departing pipeline riser.\nUnion Oil Company of California appreciates your cooperation in this matter. If you concur with\nour interpretation of the point of jurisdictional change as indicated on the attached typical\nschematic, please sign and return the attached copy for our records.\nYours very truly,\nUNION OIL COMPANY OF CALIFORNIA\nCalvin F. Broussard\nProduction Technician\ndal\\192.1-a\\1\\78-07-17\n2","truncated":false,"body_characters":2509}