{"operation":"document","citation":"PI-95-006","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1995-03-02","effective_on":null,"summary":"PI-95-006 response to Memo: Internal concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1995/PI95006.pdf","body":"<<<PAGE 1>>>\n\nMemorandum\nMarch 2, 1995\nINFORMATION: U.S. Oil Interpretation\nCesar De Leon\nDeputy Associate Administrator for Pipeline Safety\nIvan Huntoon\nDirector, Central Region\nThis responds to your memo of February 9, 1995, regarding our January 30, 1995, letter to Mr.\nThomas J. Sullivan, consultant for the U.S. Oil Company. We advised Mr. Sullivan that the Part\n195 regulations cover the company’ s pipelines outside the terminal, except for a pipeline\ntransporting calcium chloride. Your memo asks whether, before the 20% SMYS amendment,\nPart 195 applied to a low-stress line segment between the West Shore connection and the\nterminal. You believe Part 195 did apply since the line segment serves as a continuation of West\nShore’ s pipeline, which operates at more than 20% SMYS.\nWe have interpreted the low-stress exclusion to apply only to pipelines that operate entirely at\n20% SMYS or less. So, for Part 195 to have applied to the line segment in question, the segment\nwould have had to have been part of a pipeline that operated above 20% SMYS. Although Part\n195 does not define the beginning and end of pipelines, it does place the burden of compliance\nwith the regulations on persons who own or operate pipelines. Therefore, in the absence of any\nother demarcation of pipelines under Part 195, the only reasonable way to apply the low-stress\nexclusion is on the basis of pipeline ownership or operation. Using this approach, because the line\nsegment in question was owned and operated separately from the West Shore pipeline, the\nsegment was not under Part 195 before the 20% SMYS amendment.\n#\ndal/195.1\n95-03-02","truncated":false,"body_characters":1626}