{"operation":"document","citation":"PI-80-018","title":"Cities Service Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1980-10-10","effective_on":null,"summary":"PI-80-018 response to Cities Service Company concerning 195.402.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/PI80018.pdf","body":"<<<PAGE 1>>>\n\nOct 10 1980\nMr. R. S. Hutton\nManager-Production\nGulf of Mexico Region\nCities Service Company\nBox 22082\nHouston, TX 77027\nDear Mr. Hutton:\nYour letter dated July 1, 1980, requested a waiver from\ncompliance with 49 CFR Part 195 concerning the requirements for a\nprocedural manual for operation, maintenance, and emergencies for\nan offshore 8\" crude oil pipeline connecting Eugene Island Block\n258 \"B\" Platform to Eugene Island Block 259 \"A\" Platform, a\ndistance of 4 1/2 miles approximately. The basis of your request\nis that a procedural manual is unwarranted considering the broad\nscope of the regulations together with the absence of hazardous\nconditions that could develop with this particular pipeline.\nThe regulations are necessarily broad to cover the various\nsituations in the industry. However, in the event that a\nparticular regulation addresses a situation which you do not have\n(i.e., ?195.402(e)(6) which requires assisting with halting\ntraffic on roads and railroads), then clearly, you would not be\nexpected to include procedures for this situation in your manual.\nLikewise, regulations need not be met that do not apply to your\npipeline, such as ?195.402(e)(8), which applies only to pipelines\ntransporting highly volatile liquids.\nConcerning your statement that there is an absence of hazardous\nconditions that could develop with your pipeline, we presume you\nhave based this conclusion on the nature of the conditions under\nwhich the pipeline operates and the operating practices that are\nfollowed. Even so, the purpose of Part 195 is to assure a\nuniform level of safety throughout the industry. Waivers are\ngranted only for unusual circumstances that would make compliance\nwith a Part 195 requirement inappropriate. We do not find that\nthe conditions and practices you have described would justify a\nwaiver under these criteria.\nIn view of the foregoing, your request for a waiver is denied.\nSincerely,\n\\signed\\\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\ndal\\195\\402\\80-10-10\n1\n\n<<<PAGE 2>>>\n\nMaterials Transportation Bureau\ndal\\195\\402\\80-10-10\n2","truncated":false,"body_characters":2108}