All American Pipeline Company — Pipeline Safety Interpretation

Page 1July 12, 1996 Mr. Jordan R. Janak, R.E.M. Director, Regulatory Compliance All American Pipeline Company 5500 Ming Avenue Suite 300 Bakersfield, CA 93309 Dear Mr. Janak: This is in response to your request for an interpretation whether pump unit drivers are included in the definition of “ pipeline system” in 49 CFR 195.2. The definition of “ pipeline system” is limited to those pipeline facilities through which a hazardous liquid or carbon dioxide moves in transportation. The pump unit drivers do not have either a hazardous liquid or carbon dioxide moving through them so they are not a part of the “ pipeline system.” However, the pump unit drivers would come under the definition of a “ pipeline facility.” If I can be of further assistance, please contact me. Sincerely, Richard D. Huriaux. Director for Technology and Standards Office of Pipeline Safety Lloyd Ulrich: brw 202/366-4395 6/12/96 cc: DPS-12,10,20 Regions: TSI e-mail Rdg. File State Mailing A: Janak-pu.mp#