{"operation":"document","citation":"PI-96-026","title":"California Department of Forestry and Fire Protection — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-02-15","effective_on":null,"summary":"PI-96-026 response to California Department of Forestry and Fire Protection concerning 195.12.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-026.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-026.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-026","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96026.pdf","body":"<<<PAGE 1>>>\n\nFebruary 15, 1996\nMs. Nancy Wolfe\nChief, Pipeline Safety and Enforcement\nOffice of the State Fire Marshall\nCalifornia Department of Forestry and Fire Protection\nSuite 600\n7171 Bowling Drive\nSacramento CA 95823-2034\nDear Ms. Wolfe:\nWe have considered your letter of January 25, 1996, submitted under 49 CFR 190.9, concerning a\nrequest by the ARCO Pipe Line Company for an administrative finding under 49 CFR 195.120 (b) (7) .\nThis regulation permits us to find that particular piping is impracticable to design and construct to\naccommodate the passage of instrumented internal inspection devices. Such a finding excludes the piping\nfrom the requirement of § 195.120 (a) that \"each new pipeline and each line section of a pipeline where\nthe line pipe, valve, fitting or other line component is replaced; [sic] must be designed and constructed to\naccommodate the passage of instrumented internal inspection devices.\"\nARCO's request pertains to its intrastate pipelines in the Los Angeles Basin that are not \"currently\ncapable of passing internal inspection devices using existing technology.\" ARCO excluded from its\nrequest crude transmission lines #63 and #90, and any pipelines it may replace or relocate. You\nrecommended that we grant ARCO's request because present easements are inadequate for designs that\nwould allow instrumented pigging, and additional easements are either extremely costly or unavailable.\nYou are also concerned that rigid application of § 195.120 would cause ARCO to shift available funds\naway from higher priority safety-related projects.\nWe agree that under the circumstances presented it would be difficult for ARCO to obtain additional\nright-of-way to provide for instrumented pigging of a line section whenever a line component is replaced.\nHowever, to offset the reduction in safety if such right-of-way is not obtained, we believe ARCO should\napply more rigorous corrosion inspections on the line sections. We, therefore, find that line sections in\npipelines covered by ARCO's request are impracticable to design and construct to accommodate the\npassage of instrumented internal inspection devices, provided ARCO uses close-interval surveys to\ninspect the line sections for corrosion each time such inspections are required under 49 CFR Part 195.\nSincerely,\nRichard B. Felder\nAssociate Administrator for Pipeline Safety\n06/11/99 195.120\n96-02-15.doc","truncated":false,"body_characters":2393}