{"operation":"document","citation":"PI-17-0001","title":"G2 Partners — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-12-08","effective_on":null,"summary":"PI-17-0001 response to G2 Partners.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/56606/g2-partners-pi-17-0001-10-23-2017-part-1921-and-1950.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nO CT 2 3 2017\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. John A. Jacobi\nVice President and Principal\nG2 Partners\n10850 Richmond A venue, #200\nHouston, T)\\1 77042\nt2\nDearMr/ uui:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nDecember 16, 2016, you requested an interpretation of the reporting requirements for 49 CFR\nParts 192 and 195. You specifically requested clarification on the reporting requirements in\nDOT Form PHMSA F 7000-1.1 for hazardous liquid pipeline facilities and DOT Form\nPHMSA 7100.2-1 for gas pipeline facilities.\nYou stated your understanding is that \"if a line has never been placed in service, it should not be\nplaced on an annual report or reported to the National Pipeline Mapping System (NPMS).\" You\nprovided reasons why SOil,le pipelines may be properly designed to meet PHMSA regulations but\nhave never had product introduced, such as where the construction of planned connections has\nnot been completed. You asked if an operator needs to report information to PHMSA using\nDOT Forms PHMSA F 7000-1.1 and PHMSA 7100.2-1 and the NPMS for a pipeline that has\nnever been placed in service and has never transported a PHMSA regulated product.\nThe Federal pipeline safety regulations do not require operators to submit DOT Form PHMSA\nF 7000-1.1 for hazardous liquid pipeline facilities and DOT Form PHMSA 7100.2-1 for gas\npipeline facilities or report information using NPMS until a regulated pipeline is placed in\nservice. Once the pipeline is in service, the operator must report using DOT Form PHMSA\nF 7000-1.1 for hazardous liquid pipeline facilities and DOT Form PHMSA 7100.2-1 for gas\npipeline facilities, as well as NPMS, for the life of the pipeline until it is formally abandoned.\nlfwe can be of further assistance, please contact Tewabe Asehe at 202-366-5523.\nSincerely,\n, «:A. e ...\n~ ~i:ctor, Office of Standards\nand Rulemaking ,\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulat10ns to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enfor~.::able rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\nDecember 16, 2016 VIA E-Mail\nMr. John Gale, Director\nStandards & Rulemaking\nOffice of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration (PHP-30)\nU.S. Department of Transportation\n1200 New Jersey Avenue S.E.\nWashington, DC 20590-0001\nRe: Request for Interpretation – Annual Reports under Parts 192 and 195\nDear Mr. Gale:\nThe hazardous liquid annual report instructions clearly state: “Each operator must annually\ncomplete and submit DOT Form PHMSA F 7000–1.1 for each type of hazardous liquid pipeline\nfacility operated at the end of the previous year.”\n(HL_Annual_Instructions_PHMSA_F_7000_1_1_rev6_2014[1].pdf, page 1 – emphasis added)\nThe gas transmission annual report instructions clearly state: “Each operator of a transmission\nor a gathering pipeline system must submit an Annual Report for that system on DOT Form\nPHMSA 7100.2-1. This report must be submitted each year, not later than March 15, and\nprovide information about the pipeline system as of December 31 of the previous year.”\n(GT_GT_Annual_Instructions_PHMSA_F_7100.2_1_(rev10_2014)[1].pdf, page 1 – emphasis\nadded)\nQuestion 5 of the National Pipeline Mapping System (NPMS) Transmittal letter reads: “Does this\npipeline data reflect conditions in the field as of December 31 of last year?” (NPMS Operator\nStandards, page 24 – emphasis added).\nMy understanding has always been that if a line has never been placed in service, it should not\nbe placed on the annual report or reported to the National Pipeline Mapping system.\nThere are pipelines that have been properly designed and constructed under the pipeline safety\nregulations (49 CFR Parts 190 -199); that have been inspected by PHMSA pipeline inspectors\nand/or state pipeline safety inspectors; that have never been connected to any other\njurisdictional facility; and that have never had product introduced for transportation or any\nother purpose.\nThere are numerous potential reasons for such circumstances. For example, the economic need\nfor the affected pipeline may have disappeared. There may be elements (such as valves,\nmeasurement, or overpressure protection) that are back-ordered but necessary before the line\ncan be commissioned. Other operators may not have completed construction of facilities that\nthe newly constructed pipeline must connect to. The upstream connections (transmission,\ngathering or production) may not be available. The newly constructed facilities may be designed\n\n<<<PAGE 3>>>\n\nG2 Partners\nPage 2 of 2\nunder Part 195 and now may be repurposed and converted to Part 192 service prior to\ncommissioning (or vice versa), ad infinitum.\nWhile it is understood that such pipelines must be properly maintained and suitability for\nservice must be documented prior to commissioning, pipelines that have never had product\nintroduced present little, if any, risk to the public.\nThe critical date appears to be December 31: If pipeline has never been placed in service, it\nshould not be reported on annual reports or reported to the NPMS.\nIf, on the other hand, a pipeline is reported on either the annual report it must also be reported\nto the NPMS or vice versa.\nYour written guidance regarding this matter is hereby requested.\nShould you have any questions please do not hesitate to contact me at 832-712-3098 or via e-\nmail at john.jacobi@g2-is.com.\nYour prompt attention to this matter would be greatly appreciated.\nSincerely,\nJohn A. Jacobi, P.E., J.D.\nVice President and Principal","truncated":false,"body_characters":5991}