# United States General Accounting Office — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-90-014
- **title:** United States General Accounting Office — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1990-03-27
- **effective on:** Not available
- **summary:** PI-90-014 response to United States General Accounting Office concerning 195.1.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-014.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-014.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-014
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1990/PI90014.pdf
**body:**

<<<PAGE 1>>>

Martin J. Fitzgerald Esq.
Special Assistant to the General Counsel
United States General Accounting Office
Washington, D. C. 20548
Dear Mr. Fitzgerald:
You have asked for our views on whether the Department of Energy
(DOE) of the Department of Transportation (DOT) has jurisdiction
over the safety the maintenance of the pipelines through which
petroleum products from the Strategic Petroleum Reserve (SPR) would
be transported to the existing system of commercial oil
distribution in the event of a drawdown from the SPR. (As to the
existing system of commercial pipelines to which the SPR connects,
we take it there is not question that DOT authority applies.) In
considering this question, we have consulted with DOE.
Under the Hazardous Liquid Pipeline Safety Act of 1979 (HLPSA), 49
USC app. 2001 et seq., DOT establishes minimal Federal safety
standards for transportation of hazardous liquids (including
petroleum) and for pipeline facilities. The standards apply to
each person who engages in transportation of hazardous liquids or
who owns or operates pipeline facilities. The term "person,"
however, does not include the Federal Government. The legislative
history makes clear that HLPSA was not intended to apply to a
Federally operated facility."
DOE has advised us that it is in operational of the SPR pipeline
facilities and has assumed responsibility for their maintenance and
safety. Based or these assurances, we do not believe that DOT's
authority under HLPSA applies to DOE's ownership and operation of
the SPR pipeline facilities. In light of our experience and
expertise in the transportation of liquids by pipeline, we have
offered to DOE whatever assistance it might need to assure that the
pipelines are being maintained and operated safety.
Please let me know if we can provide any other assistance in this
matter.
Sincerely,
C. Dean McGrath, Jr.
Associate General Counsel
DB
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