{"operation":"document","citation":"PI-93-018","title":"Snell & Wilmer Law Offices — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-04-22","effective_on":null,"summary":"PI-93-018 response to Snell & Wilmer Law Offices concerning 194.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93018.pdf","body":"<<<PAGE 1>>>\n\nApril 22, 1993\nMr. Sean M. Sherlock\nSnell & Wilmer\nLaw Offices\nSuite 1200\n1920 Main Street\nIrvine, CA 92714\nDear Mr. Sherlock:\nThis is in response to your letter of February 10, 1993, to Mr. Lloyd Ulrich pertaining to\ntelephone conversations with him concerning the requirements of 49 CFR Part 194, the Interim\nFinal Rule on Response Plans for Onshore Oil Pipelines.\nSpecifically, you requested confirmation that a line section which is excepted under Section\n194.101(b)(2)(i) would be excepted from all the requirements under 49 CFR Part 194 including\ncalculation of a worst case discharge to be used in response planning. Section 194.101(b)(2)(i)\ncontains the exception for a line section greater than 6 5/8 inches in outside nominal diameter and\ngreater than 10 miles in length where the operator determines that it is unlikely that the worst case\ndischarge from any point on the line section would adversely affect, within 12 hours after\ninitiation of the discharge, any navigable waters, public drinking water intakes, or environmentally\nsensitive areas.\nSection 194.101(b) excepts certain pipelines and line sections from the provisions of 49 CFR Part\n194. A pipeline or line section included in one of the exceptions is not required to comply with\nany of the provisions of 49 CFR Part 194 including the calculation of a worst case discharge. Of\ncourse, the worst case discharge volume needs to be calculated for the operator to support the\nexception under Section 194.101 (b)(2)(i), which is based on the worst case discharge not\nreaching certain areas within 12 hour of the release. However, the calculation does not need to be\nsubmitted to the Research and Special Programs Administration.\nI hope this responds fully to your inquiry.\nSincerely,\nCesar De Leon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\ndal\\194.101\\93-04-22","truncated":false,"body_characters":1858}