{"operation":"document","citation":"PI-93-006","title":"Amoco Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-02-05","effective_on":null,"summary":"PI-93-006 response to Amoco Corporation concerning 194.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93006.pdf","body":"<<<PAGE 1>>>\n\nFebruary 5, 1993\nYour\nMr. Eric L. Nitcher\nAmoco Corporation\nLaw Department/Amoco Building\n1670 Broadway\nP.O Box 800\nDenver, CO 80201\nDear Mr. Nitcher:\nI am writing in response to your letter of January 22, 1993,\nconfirming a telephone conversation with Mr. Lloyd W. Ulrich\nconcerning the recently published interim final rule on response\nplans for onshore oil pipelines (58 FR 244; January 5, 1993;\nadopting Part 194, Title 49, Code of Federal Regulations). letter states:\nIt is Amoco's understanding, after discussions with your\noffice, that the above referenced Interim Final Rules do not\nrequire the formulation and implementation of a response\nplan where the facilities at issue are gas gathering\npipelines or oil flow lines from the wellhead to a separator\nand/or storage tank battery. It is our understanding, that\nthe Department of Transportation is not attempting to and\ndoes not intend for the Interim Final Rules referenced above\nto cover these types of facilities.\nUnder Executive Order 12777, and delegations of authorities under\nthat order from the Secretary of Transportation to the\nAdministrator of the Research and Special Programs Administration\n(RSPA) (57 FR 62483; December 31, 1992), the requirements for\nspill response planning by operators of on-shore pipeline\nfacilities (including the submission of plans to RSPA) only apply\nto transportation-related facilities. We have reviewed the\napplication of Part 194 to the pipeline facilities you have\ndescribed, that is, lines from the wellhead to a separator and/or\nstorage tank battery, and have determined that Part 194 does not\napply to those facilities because they are not transportation-\nrelated. This opinion is consistent with the terms of a\nMemorandum of Understanding between the Department of\nTransportation and the Environmental Protection Agency (EPA) (36\nFR 24080; December 18, 1971), which was executed to assure\neffective implementation of the Federal Water Pollution Act\n(which the Oil Pollution Act (OPA) of 1990 amends). Under the\nterms of that Memorandum, we consider the lines at issue to be\n\"non-transportation related\" facilities and not subject to the\ndal\\194.0\\93-02-05\n1\n\n<<<PAGE 2>>>\n\nDepartment's regulations. You should note, however, that these\nlines may be subject to OPA requirements the EPA may adopt.\n2\nI trust that this information is responsive to your request. If\nyou have further questions about this or other matters, please\nlet me know.\nSincerely,\nCesar De Leon\nDirector Regulatory Programs\nOffice of Pipeline Safety\ndal\\194.0\\93-02-05\n2","truncated":false,"body_characters":2559}