{"operation":"document","citation":"PI-94-014","title":"BP Oil Pipeline Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-03-08","effective_on":null,"summary":"PI-94-014 response to BP Oil Pipeline Company concerning 195.402.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94014.pdf","body":"<<<PAGE 1>>>\n\nMarch 8, 1994\nMr. L. S. Abraham\nHealth & Compliance Officer\nBP Oil Pipeline Company\n812 E. National Road\nVandalia, OH 45377-3016\nDear Mr. Abraham:\nThis responds to your letter of December 16, 1993, to George W. Tenley, Jr., concerning the\nsafety regulation in 49 CFR 195.402(c)(4). This regulation requires operators to prepare and\nfollow procedures for “ determining which pipeline facilities are located in areas that would require\nan immediate response by the operator to prevent hazards to the public if the facilities failed or\nmalfunctioned.” You asked whether your company’ s policy of responding immediately to any\nfailure or malfunction regardless of location would meet this requirement.\nThe question arises because, according to your letter, some of our inspectors consider your\ncompany’ s compliance policy to be incomplete. You said they have asked your company to\nidentify environmentally sensitive, highly populated, industrial, and agricultural areas along its\npipelines, to establish response priorities, and state how your company will respond to each area.\nWe included a statement of the intent of § 195.402(c)(4) in the final rule document (44 FR 41198;\nJuly 16, 1979) and in the reconsideration document (44 FR 70165; December 6, 1979). The\nintent was to require operators to analyze their systems to identify those facilities that would\ncause hazards to the public if failure or malfunction occurred. The reconsideration document also\nnoted that the location of a facility largely determines whether it might become hazardous to the\npublic.\nWe agree with our office’ s inspectors that your company’ s procedures are incomplete.\nI hope this information is helpful to you. Please let me know if I can provide further assistance.\nSincerely,\nCesar De Leon\nDirector,\nOffice of Pipeline Safety Regulatory Programs\ndal/195.402\n94-03-08.doc","truncated":false,"body_characters":1868}