{"operation":"document","citation":"PI-73-030","title":"James H. Collins — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-10-24","effective_on":null,"summary":"PI-73-030 concerning 192.111, 192.3, 192.453, 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73030.pdf","body":"<<<PAGE 1>>>\n\nOctober 24, 1973\nMr. James H. Collins\nElectrical-Mechanical Engineer\n1310 Short Street\nNew Orleans, LA 70118\nDear Mr. Collins:\nThis is in response to your letter of September 25, 1973, to our Houston Regional Field Office\nwhich was forwarded to this office for reply.\nYour letter indicates that the gas system concerned is an intermediate pressure (typically 25 psi)\ndistribution system, serving the buildings on a college campus and owned by the college. Gas is\nsupplied through a regulator-metering station from odorized mains of a gas service utility\ncompany. The system comprises approximately 4.5 miles of welded steel mains and service lines\n5 inch to 1 1/2 inch diameter, serving 45 regulators at campus buildings, installed largely prior to\n1970. Cathodic protection was installed in June 1971, monitored weekly at key points by owner-\npersonnel, and checked so far at 16-month intervals by a corrosion engineer.\nThe gas system as described raises the jurisdictional question of whether the pipelines on the\ncollege campus constitute a master meter system subject to the Federal gas pipeline safety\nregulations or whether the college is the ultimate customer and therefore the lines in the college\nare not subject to the regulations. In order to assist you in making this determination, if the\ncollege owned gas system consumes the gas and provides another type of service such as heat or\nair conditioning, to the individual buildings, then the college is not engaged in the distribution of\ngas. In this instance the college would be the ultimate consumer, and the Federal pipeline safety\nstandards would only apply to mains and service lines upstream of the meter.\nIf the college owned gas system provides gas to consumers such as concessionaires, tenants, or\nothers, it is engaged in the distribution of gas, and the persons to whom it is providing gas would\nbe considered the customers even though they may not be individually metered. In this situation\nthe pipelines downstream of the master meter used to distribute the gas to these ultimate\nconsumers would be considered mains and service lines subject to the Federal pipeline safety\nstandards.\nThe answers to your specific questions are predicated on the assumption that this system is a\ndistribution system subject to the jurisdiction of the Federal pipeline safety standards.\nQuestion 1. Is an annual report on the monitoring and engineering check of the cathodic\nprotection required to be made by the owner (the college) and if so on what Form?\nDAL\\192\\3\\73-10-24\n1\n\n<<<PAGE 2>>>\n\nAnswer. Section 192.453 of the Code of Federal Regulations requires that all phases of work\nperformed during design, installation, operation and maintenance including recordkeeping in\nconnection with corrosion control be carried out by, or under the direction of a person qualified\nby experience and training in pipeline corrosion control methods.\nAn annual report to the Office of Pipeline Safety (OPS) on the monitoring and engineering check\nof the cathodic protection of a gas pipeline is not currently required and there are no Federal\nforms for this purpose. However §192.491 does require each operator to keep records in\nsufficient detail to demonstrate the adequacy of his corrosion control measures or that a corrosive\ncondition does not exist.\nQuestion 2. Is an annual report on leaks from any cause required to be made by the owner, and if\nso on what Form?\nAnswer. Section 191.11, 49 CFR requires that each operator of a distribution system submit an\nannual report on Department of Transportation Form DOT-F-7100.1-1 (copy enclosed) not later\nthan February 15 for the preceding calendar year.\nYour attention is also directed to Section 191.5, 49 CFR which sets out the requirements for\ntelephonic notice of certain leaks by all gas operators.\nQuestion 3. Is a gas detector leakage survey required by OPS regulations, per No. 192.723, and\nif so, per (b)(1) as in a business district at 1-year intervals, or per (b)(2) as a system outside of\nprincipal business areas, at intervals not exceeding 5-years. What Form is available for the report\nto OPS?\nAnswer. Your attention is directed to the language of paragraph (b) of Section 192.723, stating\nthat the type and scope of the leakage control program must be determined by the nature of the\noperations and local conditions, but it must meet the minimum requirements of a gas detector\nsurvey (1) at least once a year in business districts, and (2) as frequently as necessary, but at least\nevery 5 years, outside the principal business areas. In the interest of continuing safe pipeline\noperation it is contemplated by this section that whenever local conditions warrant it surveys will\nbe conducted more frequently than once a year in business districts, and more frequently than\nevery 5 years outside the municipal business areas. It follows that there may very well be\ninstances in which conducting a survey only once a year in a particular business district, or only\nonce in 5 years in a particular area outside of the principal business district would be considered\ninadequate. An evaluation of the potential hazard due to the nature of buildings such as those on\ncampus and the specific condition and environment of the pipeline system could indicate that\nconsideration to conducting leakage surveys \"as frequently as necessary\" would mean more\nfrequently than the minimum interval of 5 years.\nThe answer to the recordkeeping and report filing requirement in question one also applies here.\nDAL\\192\\3\\73-10-24\n2\n\n<<<PAGE 3>>>\n\nQuestion 4. Are periodic tests of odorization per No. 192.625 required of the owner or is he\ncovered by tests made by the supply utility company?\nAnswer. Section 192.625(f), 49 CFR, requires that each operator shall conduct periodic sampling\nof combustible gases to assure the proper concentration of odorant in accordance with this\nsection. Based on the assumption that the college is operating a gas distribution system, periodic\ntests of odorization by the owner are required.\nThe enclosed literature includes Parts 190 and 192 which you requested.\nWe trust that this will clarify the matter for you. If we can be of further assistance to you, please\nlet us know.\nSincerely,\n\\signed\\\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nEnclosures\nDAL\\192\\3\\73-10-24\n3","truncated":false,"body_characters":6324}