{"operation":"document","citation":"PI-73-006","title":"State of Louisiana Department of Justice — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-01-26","effective_on":null,"summary":"PI-73-006 response to State of Louisiana Department of Justice concerning 192.13.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73006.pdf","body":"<<<PAGE 1>>>\n\nJanuary 26, 1973\nMr. Michael A. Duplantier\nSpecial Counsel\nState of Louisiana\nDepartment of Justice\n194 Supreme Court Building\n301 Loyola Avenue\nNew Orleans, Louisiana 70112\nDear Mr. Duplantier:\nThis is in further response to your letter of December 29, 1972, to Mr. Marshall W. Taylor of our\nHouston Office which was referred to this office and acknowledged on January 10, 1973.\nIn your letter you asked for an evaluation of the situation as to possible violations of Federal gas\nsafety regulations involving the Southern Natural Gas Company's 20-inch natural gas pipeline\ncrossing of the Tangipahoa River above Hammond, Louisiana. You state that the pipeline has\nbeen partially exposed due to the erosive actions of the river and, for corrective action, the\nCompany has installed a series of 36 Henson spur jetties extending out into the river.\nYour letter suggests that the pipeline may presently be in violation of several of the Federal gas\nsafety regulations. The factual basis for our preliminary evaluation of compliance with the\nregulations derives from the information contained in your letter, from other information made\navailable through our Houston Office, and from trade journal reports of spur jetty protection of\npipeline river crossings. You ask first whether the current erosion prevention efforts make the\npipeline subject to the requirements for new pipelines under section 192.13(b). That section,\nhowever, refers to segments of pipelines replaced, relocated, or otherwise changed after the given\ndate. In your situation, the Company is employing a rather widely accepted method of restoring\nthe river bank which will cover over the pipeline and thereby maintain physical support for it.\nSince it does not appear that a pipeline segment is in any way being replaced, relocated, or\notherwise changed, that section of the regulations is not considered applicable.\nYour next state that section 192.317 would appear to require more stringent precautionary\nmeasures than are being applied in this case. The concern to which that section is addressed\nrelates to hazards that may cause the pipe to move or sustain abnormal loads. The rule, therefore,\nsets forth a general construction requirement rather than an operation or maintenance\nrequirement. In any event, the information furnished would not indicate a violation since the spur\njetties are understood to be rebuilding\n2\ndal\\192\\13\\73-01-26\n1\n\n<<<PAGE 2>>>\n\nthe river bank and protecting the pipeline from accidental damage by river traffic and thereby\nprotecting against pipe movement or abnormal loads.\nSection 192.613(b), to which you finally advert, concerns operation of a segment of pipeline\ndetermined to be in an unsatisfactory condition. In this regard, the overall requirement of section\n192.613 is to provide for continuing surveillance of an operator's facilities. Paragraph (a) or the\nsection lists the factors to be considered in the surveillance, and these relate to the pipeline itself.\nWe have no factual information at all suggestive that such factors, i.e., change in class location,\nfailures, leakage history, corrosion, substantial changes in cathodic protection requirements or\nunusual operating or maintenance conditions, are involved. In this situation, therefore, the\nprovisions of section 192.613(b) appear to be inapplicable.\nIn sum, based on the information available, we are unable to determine that there exist any\nviolations of Federal gas pipeline safety standards on the Southern Natural Gas 20-inch crossing\nof the Tangipahoa River.\nWe will be pleased, of course, to review any further information you may care to submit in the\nmatter, and if you have further questions, please call on us.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\13\\73-01-26\n2","truncated":false,"body_characters":3796}