{"operation":"document","citation":"PI-74-0108","title":"Arizona Corporation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-04-22","effective_on":null,"summary":"PI-74-0108 response to Arizona Corporation Commission concerning 192.13.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0108.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0108.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0108","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-04-22_Garabrant_192.13%20-%20lmxs.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0108\nApril 22, 1974\nMr.H. R. Garabrant\nArizona Corporation Commission\nUtilities Division\n1688 West Adams\nPhoenix, AR 85007\nDear Mr. Garabrant:\nThank you for you letter of April 10, 1974, asking whether the Federal Gas pipeline safety\nstandards (49CFR Part 192) require leakage surveys in advance of scheduled street repairs.\nAs you point out, section 192.723 of the standards sets forth the requirements concerning leakage\nsurveys. This section requires surveys to be made periodically as provided in the operator's\noperating and maintenance plan but not less frequently than every year or every 5 years,\ndepending on pipeline location. The section does not specifically require surveys in advance of\nstreet construction. However, if such surveys are prescribed in an operating and maintenance\nplan, then the operator concerned must conduct them. The procedures of an operating and\nmaintenance plan are as binding on the operator as the Federal standards (section 192.13(c)).\nYou enclosed a copy of the Arizona Public Service Company's operating and maintenance plan.\nWe have reviewed the plan, and it does not appear that any of its provisions would require a\nleakage survey in advance of street repairs.\nInasmuch as the Federal standards and the operating and maintenance plan do not require this\ntype of survey, compliance action based on either the standards or the plan would be\ninappropriate. However, if you feel that a leak survey should be required in advance of street\nrepairs, we suggest that your Commission adopt standards more stringent than Federal standards\nfor intrastate pipeline facilities.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n1\n\n<<<PAGE 2>>>\n\nApril 10, 1974\nMr. Joseph C. Caldwell\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20550\nDear Mr. Caldwell:\nI may have threaded on some thin ground or else I am about to do some good when I started\nquestioning one of the major gas distribution companies in Arizona as to what their policies were\nin regards to leakage surveys and repairs ahead of street improvement. A representative of the\ncompany, after receiving my letter of April 8, 1974, told me that I was exceeding my authority\nand looking into areas that belonged to the gas company operations only. This may be and I\ncould use some clarification.\nNot only does the public get upset when new streets are dug up for repairs by a utility company,\nmy personal experience in the past has shown that new street resurfacing, even a thin spray type\nseal coat on an asphalt street, slows dissipation of gas through old paving, thus causing greater\ngas migration whereby the gas in effect gets closer to a possible source of ignition or increases\nthe likelihood of planted vegetation damage adjacent to the street. As I understand it \"property\"\nis also to be protected by public law 90-481.\nAbout 25 years ago when working for a gas company, I remember investigating why it seemed\nthat so many new streets were being cut. We reached the conclusion that it was the issuance of\nrepair orders as a result of vegetation surveys and customer complaints of dying vegetation that\noccurred there before the improvement. It was also conjectured that soil vibration from heavy\nequipment could be loosening the crust around pitholes in the pipe as well as better sealing of the\nstreet. At that time for minor street improvements, we were not running a complete thorough\nleakage survey, usually only a vegetation survey which appeared to be insufficient.\nIn view of the above, when the opportunity arises(as in this case) I try to bring to light and\npromote coordination and cooperation between people involved in street improvements and the\nutility company.\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n2\n\n<<<PAGE 3>>>\n\nDOT 192.723 does not specifically cover surveys ahead of street improvements unless in\n192.723(b)(2)_ \"...must be made as frequently as necessary...\" could be construed that it is\nnecessary ahead of a street improvement due to the general knowledge. That investigation\nbeforehand helps reduce damage to streets and vegetation afterward. If the knowledge is not\ngenerally known, I consider it part of my job to spread the knowledge gained through my\nexperience for consideration.\nAlso, DOT 192.613 possible could be quoted in support of requiring such an investigation as this\nsection is sort of a catch all, but I can't really say that a street improvement is unusual - neither is\nit routine in a small town.\nI believe my best support lies under DOT 192.17 where the operator filed an operating and\nmaintenance plan. Under Section III of his plan, I believe I have justification of looking into the\naccomplishment of leakage surveys and repairs ahead of street improvements as they are a \"civic\nimprovement\".\nThe situation (not too serious at this time) somewhat puzzles me as I am reasonably sure the\ncompany involved does make such surveys in larger cities, however, they may not be actively\npursuing surveys ahead of street improvements in small towns that they serve. It also may be that\nthey are just resisting what they may consider governmental interference in their business.\nBefore I probe deeper in this, I need to know if I have a proper foundation or a leg to stand on.\nArizona has adopted no laws, rules or codes etc. that would be applicable in this case except\nthose of DOT's.\nFor the record, it should be noted that the short visit at the job site in the small town in question\nwas not a part of a formal inspection and no attempt was made to cite the gas company as you\ncan see from the attached letter. Had it been a part of a formal inspection, I would have had a gas\ncompany representative with me and we would have determined if a leakage survey had been\nconducted without the knowledge of the city personnel even though city personnel were not\naware that making a request for leakage surveys ahead of street improvements is a normal and\nproper procedure.\nAwaiting your comments.\nVery truly yours,\nArizona Corporation Commission\nH.R. Garabrant, Gas Utilities Safety Engineer\nUtilities Division\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n3\n\n<<<PAGE 4>>>\n\nENC: as stated.\nApril 8, 1974\nMr. Pete Watkins\nArizona Public Service Co.\nP.O. Box 21666\nPhoenix, AR 85036\nDear Mr. Watkins:\nOn April 3, 1974 I was returning to Phoenix and was passing through the town of Tolleson when\nI observed a Municipal Street Paving crew in the process of working on a major street\nimprovement job 5 or 6 blocks long, on 92nd Ave. North of Van Buren.\nOn stopping and talking with the crew, I found that the gas company (APS) had properly given\nthem gas pipe location information. Also, when talking to Mr. Green, the Public Works Director\nfor Tolleson, I found that he was unaware that it is in the best interest of all concerned to notify\nthe gas company and other utilities to survey their facilities for needed repairs or replacement of\nfacilities as soon as the major street improvement is budgeted, preferably at least 3 or 4 months\nahead of the proposed work.\nCould you please advise me what APS's standard practices are along this line and if you promote\nthe request for notice ahead of street improvements?\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n4\n\n<<<PAGE 5>>>\n\nMy definition of a major street improvement is the removal of old paving the width of the street,\ngrading, adding necessary ballast, compacting, and installing entirely new paving. The job may\nor may not include work pertaining to curbs, gutters and sidewalks.\nA minor improvements consists of adding 2\" or less additional paving on top of existing paving.\nI don't know if there is sufficient time available in this case, but a leakage survey and repairs if\nneeded would be desirable as it is a shame to have new streets torn up due to lack of surveys and\ncoordination of repairs.\nSincerely,\nArizona Corporation Commission\nH.R. Garabrant\nGas Utilities Safety Engineer\nUtilities Division\nARIZONA PUBLIC SERVICE COMPANY A.C.C.No. 982\nPhoenix, Arizona Original Sheet No.1\nFiled by: B. Paul Hart\nTitle: Manager, Rate Services\nDate Original Filing: FEB.10, 1970\nDistrict: All Company's Gas Areas Effective: Mar.12,1970\nComplying with Arizona Corporation Commission Amended General Order U-47 dated Nov. 17,\n1969, the following is presented as the Company's plan for operation and maintenance of gas\npipelines.\nGAS DISTRIBUTION OPERATING & MAINTENANCE PLAN\nGENERAL PLAN\nTo operate and maintain the Gas Distribution System to give adequate, safe, dependable and\neconomical gas service to all customers. This plan will comply with the regulations and\nstandards imposed upon the Company by certificates of convenience and necessity, by county\nand city franchises, and by applicable state and federal laws., orders and regulations.\nSPECIFIC PLAN\nI. New Additions\nA. Report of Additions\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n5\n\n<<<PAGE 6>>>\n\n1. Design according to standards (USA BBB.8-1968).\n2. Qualifying tests for design operating conditions (USA BBB.8-1968).\n3. Inspection reports verifying construction standards (USA BBB.8-1968).\nII. Operating Procedures\nA. There shall be methods or means of monitoring and controlling gas distribution\nsystem pressures to provide a margin for safety and to insure adequate gas\nsupplies to all customers.\nB. Records shall be maintained of gas quality, BTU and specific gravity.\nC. A periodic inspection of regulator stations, valve stations and system metering\nstations will be made. A record will be made of these inspections and ancillary\ntests, for odor, leaks, water, drips, valve operation, bleeds, vents, covers and ring,\nand encroachment of others.\nIII. Maintenance Plan\nA. The Gas Distribution System (all gas carrying pipes and equipment with\nappurtenances, protective devices and materials) will be under regular\nsurveillance as follows:\n1. Systematic patrol using mobile leak detector, where practicable.\n2. Barhole testing as necessitated by mobile inspection.\n3. Foot patrol and \"hand-held\" detectors on mains and services not accessible\nto mobile patrol.\n4. Numbers 1 through 3. to watch for vegetation signs of leakage, changes in\nsurface conditions, encroachment of other services and civic\nimprovements.\nB. As a follow up to surveys described in A above, APS will where required:\n1. Make replacement and abandonments ordered on mains and equipment\nfound unsafe under operating conditions.\n2. Accelerate patrols and leak surveys scheduled.\n3. Downgrade operating conditions, where pipe conditions require.\n4. Upgrade or delay further patrols/inspections, when pipe and leakage tests\nwarrant.\nC. Repairs made and tested shall be reported as completed.\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n6\n\n<<<PAGE 7>>>\n\nD. Abandonments records shall be made from orders directing this action.\nIV. Emergency Plan pursuant to USA B31.8-1968 will be maintained.\nV. Welders qualifications test shall be in accordance with USA B31.8-1968 and references,\nwhich include sampling of field welds selected for quality control.\nVI. Pipeline Inspection Reports (corrosion)\nWhenever the pipe distribution system is uncovered, a pipe inspection report shall be\nmade on suitable form and entered in record.\nVII. Odor reports shall be made from monthly tests and random points.\nVIII. Cathodic records shall show test conducted on the basis of engineering requirements.\nIX. Safety rules shall be promulgated for all classifications of APS personnel working with\nthe Gas Distribution System.\nX. Accidents/incidents will be reported as required by applicable law and regulations.\nXI. Public information program for location and underground facilities and full-time service\npersonnel on call for emergency service are maintained.\nDB\nC:\\WP51\\INTERPRT\\192\\723\\74-04-22\n7","truncated":false,"body_characters":11774}