{"operation":"document","citation":"PI-93-011","title":"California State Fire Marshal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-03-03","effective_on":null,"summary":"PI-93-011 response to California State Fire Marshal concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93011.pdf","body":"<<<PAGE 1>>>\n\nMarch 3, 1993\nMr. James Wait\nDivision Chief, Pipeline Safety\nCalifornia State Fire Marshal\nSuite 600\n7171 Bowling Drive\nSacramento, CA 95823-2034\nDear Mr. Wait:\nI apologize for not responding sooner to your letter of July 7,\n1992, regarding pipelines associated with marine terminals. You\nasked us to explain the limits of jurisdiction under 49 CFR Part\n195 over pipelines in marine terminals shown in drawings attached\nto your letter, assuming the pipelines operate above 20 percent of\nSMYS.\nUnfortunately, because we lack on-site familiarity with the\nfacilities in your drawings, we cannot definitely state which ones\nwould be covered by the regulations if they were operating above 20\npercent of SMYS. However, I believe you will find the \"Liquid\nDrawings\" in the Pipeline Safety Regulations manual provided by the\nTransportation Safety Institute (TSI) useful in answering your\nquestions. TSI used these drawings as guidelines on jurisdictional\nquestions for pipelines operating above 20 percent of SMYS. If you\nare still uncertain about jurisdiction after reviewing these\ndrawings, please consult the Director of our Western Region Office,\nEd Ondak, for further clarification.\nHopefully you will find the drawings beneficial in resolving the\nenforcement redundancy your agency is apparently experiencing with\nthe U.S. Coast Guard on lines operating at 20 percent or less of\nSMYS. Should the applicability of Part 195 be expanded to cover\nthese pipeline, we will consider the need for a memorandum of\nunderstanding with the Coast Guard as you have suggested.\nSincerely,\nCesar DeLeon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\ndal\\195.0\\1\\93-03-03","truncated":false,"body_characters":1676}