{"operation":"document","citation":"PI-95-012","title":"Bridgeline Gas Distribution, LLC — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1995-05-08","effective_on":null,"summary":"PI-95-012 response to Bridgeline Gas Distribution, LLC concerning 194.1, 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1995/PI95012.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department 400 Seventh Street, S.W.\nof Transportation Washington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nMay 8, 1995\nMr. Dennis Huddleston\nVice President, Operations\nBridgeline Gas Distribution LLC\nP.O. Box 60252\nNew Orleans, LA 70160\nDear Mr. Huddleston:\nI am responding to your letter of February 10, 1995 concerning two marine transfer lines, 2.8 miles\nlong. These lines transport natural gasoline and butane between the storage tanks of a gas\nprocessing plant and a barge dock. You asked whether the Coast Guard has authority to require\nleak testing of the lines. In addition, you asked whether the Coast Guard’ s oil spill response plan\nregulations under the Oil Pollution Act of 1990 apply to the lines instead of 49 CFR Part 194, and\nwhether the operation and maintenance requirements of 49 CFR Part 195 apply to the lines.\nBecause the Coast Guard has authority to regulate the safety of U.S. port activities, some of the\nCoast Guard’ s safety regulations may affect pipelines in port areas. However, I cannot speak\ndefinitively about the Coast Guard’ s authority to require leak testing of the two transfer lines.\nPerhaps the Coast Guard officials with whom you have been in contact can answer this question,\nor you may write the Coast Guard Commandant, 2100 Second Street, SW, Washington DC,\n20593.\nAs for response plan regulations under the Oil Pollution Act of 1990, a secretarial delegation of\nauthority gives the Research and Special Programs Administration exclusive responsibility for\npipeline response plans, except for marine transfer lines associated with motor carrier or railroad\ntransportation (1 CFR 1.53(k)(2)). Consequently, Part 194 rather than the Coast Guard’ s\nresponse plan regulations would apply to the two transfer lines.\nBesides any Coast Guard safety requirements, the safety standards in 49 CFR Part 195, including\noperation and maintenance requirements in Subpart F, apply to the two marine transfer lines. In\nLouisiana, the Department of Natural Resources has authority to enforce Part 195 against\nintrastate hazardous liquid pipelines and to apply additional or more stringent safety regulations\nthat are compatible with Part 195. Thus, the Coast Guard does not have exclusive jurisdiction\nover the two marine transfer lines.\nSW/dal/Part 194\n95-05-08 Part 194\n195.400\n\n<<<PAGE 2>>>\n\nPlease let me know if I may be of any further assistance in this matter.\nSincerely,\nCesar DeLeon\nDeputy Associate Administrator\nfor Pipeline Safety\n2","truncated":false,"body_characters":2506}