{"operation":"document","citation":"PI-03-0104","title":"Montana-Dakota Utilities Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-06-11","effective_on":null,"summary":"PI-03-0104 response to Montana-Dakota Utilities Company concerning 192.721.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-03-0104.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-03-0104.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-03-0104","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2003/g03-06-11_Lee_192.721-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-03-0104\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\nJune 11, 2003\nMr. Douglas M. Lee, P.E.\nSenior staff Engineer\nMontana-Dakota Utilities Company\n400 North Fourth Street\nBismarck, ND 58501\nDear Mr. Lee:\nThis is in response to your letter of May 14, 2003, which asks for an interpretation of 49 CFR 192.721 as\nit applies to the frequency of patrolling of gas distribution mains that are attached to an apartment building.\nSection 192.721(a), Distribution Systems: Patrolling, states that the frequency of patrolling of gas\nmains is to be determined by the gas distribution pipeline operator based on an evaluation of conditions that\ncould lead to failure or leakage, and the possible hazards to the public. Section 192.721(b) specifies patrol\nfrequencies for \"mains in places or on structures where anticipated physical movement or external loading\ncould cause failure or leakage . . .\"\nThe question is whether a gas main attached to a building is subject to \"anticipated physical movement\nor external loading\" that could cause system failure or leakage and require specific patrolling frequencies as\nspecified in § 192.721(b). Generally, pipelines installed in or on structures, including buildings and bridges, are\nnot subject to movement or loadings that could cause failure if the pipeline is designed, constructed, and\nmaintained in accordance with 49 CFR Part 192.\nMoreover, under § 192.721(a) the gas distribution pipeline company is responsible for making a\ndetermination of patrol frequency based on its evaluation of the conditions which could cause failure and\nleakage, subject to confirmation during inspections by State or Federal pipeline safety personnel.\nIf you have any further questions about the pipeline safety regulations, please contact me at (202)\n366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nMontana-Dakota Utilities Co.\n400 North Fourth Street\nBismarck, ND 58501\nMay 14, 2003\nRichard Huriaux\nOffice of Pipeline Safety, Research and Special\nPrograms Administration, U.S. Department of Transportation\n400 Seventh Street, S.W., Rm. 7128\nWashington D.C. 20590-0001\nRe: CFR 19 Part 192.721 (b)\nDear Mr. Huriaux:\nWith respect to the above referenced regulation, I have found a disparity in how many operators\ninterpret this regulation and look forward to resolution through your interpretation. The regulation\nclearly states that this additional patrolling is necessary for \"Mains in places or on structures where\nanticipated physical movement or external loading could cause failure or leakage must be patrolled\n-\". Based on this verbiage combined with operational experience of over 75 years, one could easily\nattest that pipelines properly supported on structures such as bridges or buildings are not subject to\nmovement that could cause failure or leakage. Just as stream crossings can wash out, a bridge could\nfail due to flooding conditions and a prudent operator will monitor all areas subject to movement\nfollowing any natural or man-made activity that could affect the integrity of its system.\nAttached are photographs of a \"main\" attached to an apartment complex. Based on the verbiage of\n192.721 (b), it appears that the operator is granted the discretion to either include or exclude this\npiping from quarterly or semi-annual line patrols. Can you either confirm this interpretation or provide\nadditional insight to the position held by the Office of Pipeline Safety?\nThank you for your response in this matter.\nSincerely,\nDouglas Lee, P.E.\nSenior Staff Engineer","truncated":false,"body_characters":3652}