Cities Service Company — Pipeline Safety Interpretation

Page 1Oct 10 1980 Mr. R. S. Hutton Manager-Production Gulf of Mexico Region Cities Service Company Box 22082 Houston, TX 77027 Dear Mr. Hutton: Your letter dated July 1, 1980, requested a waiver from compliance with 49 CFR Part 195 concerning the requirements for a procedural manual for operation, maintenance, and emergencies for an offshore 8" crude oil pipeline connecting Eugene Island Block 258 "B" Platform to Eugene Island Block 259 "A" Platform, a distance of 4 1/2 miles approximately. The basis of your request is that a procedural manual is unwarranted considering the broad scope of the regulations together with the absence of hazardous conditions that could develop with this particular pipeline. The regulations are necessarily broad to cover the various situations in the industry. However, in the event that a particular regulation addresses a situation which you do not have (i.e., ?195.402(e)(6) which requires assisting with halting traffic on roads and railroads), then clearly, you would not be expected to include procedures for this situation in your manual. Likewise, regulations need not be met that do not apply to your pipeline, such as ?195.402(e)(8), which applies only to pipelines transporting highly volatile liquids. Concerning your statement that there is an absence of hazardous conditions that could develop with your pipeline, we presume you have based this conclusion on the nature of the conditions under which the pipeline operates and the operating practices that are followed. Even so, the purpose of Part 195 is to assure a uniform level of safety throughout the industry. Waivers are granted only for unusual circumstances that would make compliance with a Part 195 requirement inappropriate. We do not find that the conditions and practices you have described would justify a waiver under these criteria. In view of the foregoing, your request for a waiver is denied. Sincerely, \signed\ Melvin A. Judah Acting Associate Director for Pipeline Safety Regulation dal\195\402\80-10-10 1#

Page 2Materials Transportation Bureau dal\195\402\80-10-10 2#