National Propane Corporation — Pipeline Safety Interpretation

Page 1PI-71-0105 March 24, 1971 Mr. Gerald Pohlman Great Plains Gas National Propane Corporation P. O. Box 2067 Cedar Rapids, Iowa 52406 Dear Mr. Pohlman: This is in reply to your letter of March 12, 1971, stating that it is your understanding that the Minimum Federal Safety Standards require that DOT Form F-7100-1 be filed by "anyone servicing more than then individual living quarters, such as trailer courts." The operator of the trailer court is an "operator...transport (ing) petroleum has in a system that serves ten or more customers," under Section 192.11 of these regulations, and as such is subject to all the requirements of the regulations, including those for reporting. You also ask whether the regulations apply to a motel of ten or more separate units, where each unit has its own service line feeding from a common main which, in turn, is supplied from a single storage tank, either with one meter serving all units, or alternatively. with a separate meter at each unit. From the safety viewpoint, there is no difference between the trailer court operator and the motel operator, and the regulations apply in both instances. If we can be further assistance, please let us know. Sincerely, Joseph C. Caldwell Director, Acting Office of Pipeline Safety#

Page 2Great Plains Gas National Propane Corporation P.O. Box 2067 1101 Second Avenue S.E. Cedar Rapids, Iowa 52406 March 12, 1971 Secretary of Transportation Washington D.C. 20590 ATTENTION: Joseph C. Caldwell Dear Mr. Caldwell: Thank you for your reply to my letter, I'm sorry I wasn't too clear about the information I need. It is my understanding that D.O.T. regulations require anyone servicing more than ten individual living quarters, such as trailer courts, is required to fill out D.O.T. Form F71001-1. My other question was to see if these same regulations apply to a motel of ten or more units where each unit has its own service line feeding from a common main which in turn is from a single storage tank? I will attach a drawing to try to show what I mean. These, of course, could be used with one meter serving all units or a separate meter at each unit. Sincerely, Gerald Pohlman#