{"operation":"document","citation":"PI-73-0103","title":"Alan H. Smith Consulting Engineers, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-02-20","effective_on":null,"summary":"PI-73-0103 response to Alan H. Smith Consulting Engineers, Inc. concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-02-20_Whitelock_192.3_Service%20Line-xs.pdf","body":"<<<PAGE 1>>>\n\nPI-73-0103\nFebruary 20, 1973\nMr. A. Roy Whitelock\nPlumbing Engineer\nAlan H. Smith Consulting Engineers, Inc.\n8700 Stemmons Freeway, Suite 407\nDallas, Texas 75247\nDear Mr. Whitelock;\nYour letter of January 25, 1973, addressed to our Houston office has been referred to this office for reply. In your letter\nyou asked for information regarding gas pipeline corrosion and the role of the consulting engineer.\nFederal safety standards for the transportation of natural and other gas by pipeline are contained in Part 192, Title Code\nof Federal Regulations, a copy of which is enclosed. Subpart I of Part 192 sets forth the requirements for corrosion\ncontrol. Those particular requirements were adopted as Amendment 192-4, issued on June 25, 1971, with and effective\ndate of August 1, 1971.\nAs you will note in section 192.453, the Subpart I requirements are applicable to operators, and the term “operator” is\ndefined in section 192.3 as a person who engages in the transportation of gas. This Department issues no regulations\ndirected to consulting engineers as such. An operator is free to employ or otherwise utilize the services of a consulting\nengineer if he so chooses. The Department is not concerned with such arrangements, but will look to the operator for\ncompliance with all applicable regulations.\nYou have also asked with regard to jurisdiction over service lines on private properties which have two or more service\nrisers. Service line is presently defined in section 192.3 as a distribution line that transports gas to a customer meter set\nassembly from a common source of supply. Thus, any pipeline coming within the definition of service line is subject to\nthe applicable regulations irrespective of whether it is on private property or has two or more service risers.\nAt the state level, insofar as intrastate gas pipeline facilities are concerned, a State agency may adopt standards\nthat are in addition to, or more stringent than, the Federal safety standards. In Texas, the Texas Railroad Commission,\nDrawer 12967, Capitol Station, Austin, Texas 78711, has assumed responsibility for the safety regulation of intrastate gas\npipeline facilities. You may, therefore, wish to contact that agency for any information it may have relevant to your\ninquiry.\nIf we may be of further assistance in this matter, please call on us.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nAlan H. Smith Consulting Engineers, Inc.\n8700 Stemmons Freeway, Suite 407\nDallas, Texas 75247\nJanuary 25, 1973\nU. S. Government\nDepartment of Transportation\nOffice of Pipeline Safety\n201 Fannin St., Room 319\nHouston, Texas 77002\nDear Sirs:\nIn a recent meeting of the Dallas/Ft. Worth chapter of the American Society of Plumbing Engineers we discussed the\nConsulting Engineer's roll in the problem of pipeline corrosion. It is my understanding that your office is now the\ngoverning body for all pipeline installations as well as most natural gas piping installations.\nWe were informed that your jurisdiction is over any natural gas service line on private property if this line has two or\nmore service risers. We would like to know exactly what your department expects from our firm as well as other\nEngineers in the design and construction supervision of various projects. We would also like the date on which these\nactions and regulations were placed in effect and if retroactive, to what date.\nPlease send our office any available material and information you have regarding pipeline corrosion as it applies to\nConsulting Engineers. This matter has for some time been of concern to many Engineers and we are glad to see it\nclarified by your department at this time.\nThank you very much for your cooperation and assistance in this matter.\nYours very truly,\nA. Roy Whitelock\nPlumbing Engineer","truncated":false,"body_characters":3825}