{"operation":"document","citation":"PI-71-046","title":"American Petroleum Institute — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-03-30","effective_on":null,"summary":"PI-71-046 response to American Petroleum Institute concerning 192.145.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-046.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-046.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-046","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71046.pdf","body":"<<<PAGE 1>>>\n\nMr. B. H. Lord, Director\nDivision of Transportation\nAmerican Petroleum Institute\n1801 K Street, N. W.\nWashington, D. C. 20006\nDear Mr. Lord:\nThis is in reply to the petition for reconsideration filed by the American Petroleum Institute on\nOctober 26, 1970. That part of the petition which requested the inclusion of API Standard 6A in\nSection 192.145(a) of the Minimum Federal Safety Standards, was favorably acted upon by the\nspot amendment, issued on November 10, 1970. However, no action has been taken on the\nrequest for modification of Section 192.615(d), which requires that each operator shall establish\nan educational program to enable customers and the general public to recognize and report a gas\nemergency to the appropriate officials.\nNo change in Section 192.615(d) is contemplated at this time. In our view, the objections of the\nAmerican Petroleum Institute are not sufficient, since the language of this Section is sufficiently\ngeneral to allow for the operational differences between gathering lines, transmission companies\nand distributors. The nature of the \"educational program to enable customers and the general\npublic to recognize and report a gas emergency to the appropriate officials\" is not specified, and\nmay, of course, vary according to the circumstances of the individual operator. What is intended\nis that ledge of how to recognize a possible gas emergency and what authority to notify promptly.\nIt was certainly not intended, as suggested in the petition, that \"a gatherer with a few miles of\njurisdictional gathering lines would be required to spend the same amount of money and effort as\nwould a large transmission company or distribution company with thousands of miles\njurisdictional lines.\"\nAlthough the customers of gathering lines are, as argued in the petition, usually transmission\ncompanies, that is not always the case, the moreover, even on gathering lines emergencies may\noccur which effect the public as well as customers. For that reason, the request that operators of\nnatural gas gathering lines be exempted from the requirements of Section 192.615(d) is denied.\nWe agree, however, with your suggestion that the efforts of each operator shall be related to the\nsize of his operations, and that the required educational programs may be organized and carried\nout by the operators jointly through trade associations representing the various segments of the\nDB\nC:\\WP51\\INTERPRT\\192\\615\\71-03-30\n1\n\n<<<PAGE 2>>>\n\nnatural gas pipeline industry, cooperating with each other to avoid \"duplication of effort\" and\nconflicting instructions.\nWe hope this answers all your requests for clarification, and if we can be of further assistance,\nplease let us know.\nSincerely,\n/Signed/\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\615\\71-03-30\n2","truncated":false,"body_characters":2830}