# Dixie Pipeline — Pipeline Safety Interpretation

- **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:** Not available
- **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>>>

August 9, 1983
Mr. T. E. Burnett
Dixie Pipeline
P.O. Box 2220
Houston, Texas 77901
Dear Mr. Burnett:
You have asked our opinion regarding the extent of application of
the Hazardous Liquid Pipeline Safety Act (HLPSA) (19 U.S.C. 2001
et seq.) and 49 CFR Part 195.1 to the loading docks of your LP
gas storage facility at Milner, Georgia.
Our understanding of the facts is based upon representations made
in correspondence from Dixie and the Office of Comptroller
General of the State of Georgia. The LP gas is piped into
storage facilities. From the storage tanks, the gas is filtered
and piped onto the loading docks where it is metered out onto
trucks for transport both within and outside the State of
Georgia.
Although these loading docks are not currently subject to any
requirements of 49 CFR Part 195, we agree that they are subject
to the jurisdiction of the HLPSA. Thus far, however, MTB has
found no basis to issue regulations under Part 195 applicable to
such facilities.
Whether State regulatory action with respect to these facilities
is pre-empted by Federal jurisdiction is therefore, dependent on
whether the facilities are interstate facilities or intrastate
facilities. Because the distinction between the two types of
facilities has not been clearly understood by both industry and
government personnel we have developed the enclosed discussion
paper. It is hoped that the paper more clearly explains MTB's
view of the distinctions and will assist you in arriving at an
amicable resolution of the current dispute in the State of
Georgia.
Please contact me directly if you have further questions
regarding the enclosed discussion paper.
Sincerely,
Paul Biancardi
Attorney-Advisor
Enclosure
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