Pennsylvania & Southern Gas Co. — Pipeline Safety Interpretation

Page 1PI-71-0100 January 7, 1971 Mr. E. L. Lohmann Vice Presidnet Pennsylvania & Southern Gas Co. 103 S. Elmer Avenue Sayre, PA. 18840 Dear Mr. Lohmann: The interpretation you have made of 49 CFR, Section 191.11 is correct. Lines operating at or over 20% SMYS must be reported on Form F 7100.1-1. You are also correct in that you must report each of your four systems separately as covered in 49 CFR, Section 191.7. As requested, 30 copies of each form and four copies of each of the instructions are enclosed. Thank you for your interest in the pipeline safety program. Sincerely, SIGNED Joseph C. Caldwell Acting Director Office of Pipeline Safety#

Page 2Pennsylvania & Southern Gas Company 103 So. Elmer Avenue P.O. Box 188 Sayre, Pennsylvania 18840 December 22, 1970 Mr. Joseph C. Caldwell, Deputy Director Office of Pipeline Safety Department of Transportation Washington, D. C. 20590 Re: Part 191 - Reports of Leaks Dear Mr. Caldwell: We received today the following items from your office: 1 copy - Instructions for Completing DOT Form F 7100.1-1 1 copy - Instructions for Completing DOT Form F 7100.2-1 1 copy - Form F 7100.2-1 There was no copy of form F 7100.1-1 included. We assume that this form was missed in the mailing. Our Company is basically in gas distribution. We have, however, some lines operating over 20% of SMYS. Our interpretation of Part 191.11 is that we must report on both forms. We also operate in four different states, namely New York, Pennsylvania, Maryland and North Carolina. We assume that we must report each system separately either to the respective state or to your office. Please advise. A supply of 30 of each of these forms and 4 copies of each of the instruction sheets would be greatly appreciated. Thank you. Very truly yours, Pennsylvania & Southern Gas Company E.L. Lohmann, Vice President#