{"operation":"document","citation":"PI-83-014","title":"Dixie Pipeline — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-08-09","effective_on":null,"summary":"PI-83-014 response to Dixie Pipeline concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83014.pdf","body":"<<<PAGE 1>>>\n\nAugust 9, 1983\nMr. T. E. Burnett\nDixie Pipeline\nP.O. Box 2220\nHouston, Texas 77901\nDear Mr. Burnett:\nYou have asked our opinion regarding the extent of application of\nthe Hazardous Liquid Pipeline Safety Act (HLPSA) (19 U.S.C. 2001\net seq.) and 49 CFR Part 195.1 to the loading docks of your LP\ngas storage facility at Milner, Georgia.\nOur understanding of the facts is based upon representations made\nin correspondence from Dixie and the Office of Comptroller\nGeneral of the State of Georgia. The LP gas is piped into\nstorage facilities. From the storage tanks, the gas is filtered\nand piped onto the loading docks where it is metered out onto\ntrucks for transport both within and outside the State of\nGeorgia.\nAlthough these loading docks are not currently subject to any\nrequirements of 49 CFR Part 195, we agree that they are subject\nto the jurisdiction of the HLPSA. Thus far, however, MTB has\nfound no basis to issue regulations under Part 195 applicable to\nsuch facilities.\nWhether State regulatory action with respect to these facilities\nis pre-empted by Federal jurisdiction is therefore, dependent on\nwhether the facilities are interstate facilities or intrastate\nfacilities. Because the distinction between the two types of\nfacilities has not been clearly understood by both industry and\ngovernment personnel we have developed the enclosed discussion\npaper. It is hoped that the paper more clearly explains MTB's\nview of the distinctions and will assist you in arriving at an\namicable resolution of the current dispute in the State of\nGeorgia.\nPlease contact me directly if you have further questions\nregarding the enclosed discussion paper.\nSincerely,\nPaul Biancardi\nAttorney-Advisor\nEnclosure\ndal\\195\\1\\83-08-09\n1","truncated":false,"body_characters":1740}