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e <br />DOCKETS UNIT <br />PAGE THIRTEEN <br />MARCH 24, 1987 <br />(c) Do any unregulated pipelines carrying these products <br />pose a sufficient threat to public safety to warrant <br />imposition of Part 195 safety standards? <br />Response: <br />The City does not have the data needed to respond to <br />this question and would submit that no comprehensive <br />databaserpurrently exists that could provide the <br />information needed to answer this question. <br />9. Proposal: <br />Include carbon dioxide (CO2) pipelines in the regulation of <br />hazardous liquid pipelines. (Subcommittee on Fossil and <br />Synthetic Fuels) <br />Response: The U. S. Department of Transportation Research <br />and Special Programs Administration, Materials Transporta- <br />tion Bureau's "Guidebook for Hazardous Materials Incidents" <br />(DOT P5800.3) identifies carbon dioxide in all forms as <br />being hazardous to the public. As is the City's position <br />for anhydrous ammonia, any product being transported to <br />through interstate pipelines and considered to be hazardous <br />to the public or the environment should be regulated. <br />Questions: <br />(a) Do CO2 pipelines pose a sufficient threat to life or <br />property to warrant imposition of Federal safety <br />regulations? <br />Response: <br />Yes, CO2 can cause severe frost bite or death by means <br />of suffocation when a person has contact with the <br />product which has a tendency to concentrate in vapor <br />clouds in low areas. <br />(b) If Federal standards are imposed, should there be <br />exceptions for gathering or transmission lines in <br />rural areas? <br />Response: <br />Exemptions should be given only when sufficient <br />Information exists to document the fact that a <br />risk to the public or environment does not exist. <br />