Skelly Oil Company — Pipeline Safety Interpretation

Page 1PI-72-0103 2/14/72 Mr. A. A. Burkard Regional Skelgas Sales & Safety Engineer Skelly Oil Company 6000 Douglas Avenue Building Des Moines, Iowa 50322 Dear Mr. Burkard: This will acknowledge receipt of your letter of January 31, 1972, and my telephone conversation with your Mr. Kelly on February 4, 1972. As I advised Mr. Kelly over the telephone, amendment 192.11 of Title 49 of the Code of Federal Regulations issued on January 21, 1972, relieves the operators of petroleum gas systems serving less than 100 customers from the requirement of submitting an annual report for 1971. If you have any further questions regarding this matter, please contact us. Sincerely, Cesar DeLeon Operation & Compliance Officer Office of Pipeline safety#

Page 2Skelly Oil Company Marketing Department Central Region 6000 Douglas Avenue Building Des Moines, Iowa 50322 January 31, 1972 Office of the Secretary of Transportation Washington, D. C. Attention: Cesar DeLeon Operation and Compliance Officer Office of Pipeline Safety Dear Sir: Your letter of January 12, 1972, to Mr. Mel Field at 4502 Leavenworth, Omaha, Nebraska, has been referred to me. I have been wondering how you intend for us to use your forms concerning distribution lines when you are dealing in miles and miles of gas lines. Our problem is that we do have a few trailer courts piped up to one or more 1,000 gallon propane tanks and the most pipe we would have in the ground at any one location probably would be 3,000 feet. All your forms ask for how many miles. Our systems are all covered pipe and are protected with anodes, and the only pressure we run in the systems is 10 psi. If you need all this information, why can't you provide us with a form that fits our needs? A fraction of one mile is not going to provide you with much information unless your only interest is to compile statistics. May I hear from you soon so that we can meet your February deadline? Yours truly, A. A. Burkard Regional Skelgas Sales & Safety Engineer#