{"operation":"document","citation":"PI-73-015","title":"John T. Stanclift — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-06-22","effective_on":null,"summary":"PI-73-015 concerning 192.723.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73015.pdf","body":"<<<PAGE 1>>>\n\nJune 22, 1973\nMr. John T. Stanclift\n114 Woodlawn Street\nGeneva, Ohio 44041\nDear Mr. Stanclift:\nYour letter of May 23, 1973, questions two areas of the Federal gas pipeline safety regulations\nabout which you say you are concerned as a result of actions taken by the East Ohio Gas\nCompany.\nYou ask first for clarification regarding §192.453 and the company's action in transferring the\nmonitoring and maintenance of cathodically protected pipelines from the corrosion department to\nthe construction and maintenance department. Section 192.453, in pertinent part, requires that\nthe operator's procedures for the operation and maintenance of cathodic protection systems be\ncarried out by, or under the direction of, a person qualified by experience and training in pipeline\ncorrosion control methods. The company letter of April 18, 1973, a copy of which you\nforwarded, explained certain steps that are being taken, but did not indicate a violation of\n§192.453, and your letter does not explain in what respect safety may be adversely affected by the\ncompany action. This office is not in a position to comment on a company's internal organization,\nand our concern is only that the procedures be carried out by, or under the direction of, properly\nqualified personnel as required by the regulation regardless of where the personnel are placed in\nthe company's organization.\nYou also ask whether gas detection surveys must be made on the inside of buildings under the\n§192.723(b)(1) requirement that surveys be conducted yearly on distribution systems in business\ndistricts. The answer does not depend on the definition of business district, but rather on whether\nthe lines in question are classed as service lines and thereby subject to the regulations. A service\nline is defined as a distribution line that transports gas from a common source of supply to a\ncustomer meter or the connection to a customer's piping whichever is farther downstream. In the\nusual case, the customer meter serving a building is at or near the building wall, and all piping\ndownstream of the meter inside the building is customer's piping. Such piping is not included\nwithin the definition of service line and, therefore, is not subject to the gas detector survey\nrequirements of §192.723.\ndal\\192\\723\\73-06-22\n1\n\n<<<PAGE 2>>>\n\nIf you have further questions in these areas, please contact us.\nSincerely,\n/signed/\nJoseph C.Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\723\\73-06-22\n2","truncated":false,"body_characters":2477}