{"operation":"document","citation":"PI-74-0126","title":"Gulf Oil Company - U.S. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-07-18","effective_on":null,"summary":"PI-74-0126 response to Gulf Oil Company - U.S. concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0126.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0126.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0126","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-07-18_Kidd_192.1-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0126\nJul 18 1974\nMr. T. W. Kidd\nGulf Oil Company - U.S.\nProduction Department\nOklahoma City District\n600 Oklahoma Mortgage Building\nOklahoma City, OK 73102\nDear Mr. Kidd:\nThis responds to your letter of April 11, 1974, regarding the reporting of pipelines on Department\nof Transportation Form DOT F 7100.2-1 and your conversations by telephone with Mrs. Painter\nand Mr. DeLeon of our office.\nYour letter indicates that in the State of Oklahoma, the lines involved serve several Gulf leases in\na non-rural area. Low pressure residue gas (8-12 psig) is purchased from Phillips Petroleum\nCompany. Custody of the gas is taken at Gulf lease line connections and is delivered through\nGulf owned short segments of line to pumping unit prime movers and oil treating heaters on the\nlease. You letter further indicates that similar conditions exist in Kansas.\nThe advice given to you by Mr. DeLeon was based on gas moving in pipelines within a\nproduction facility used solely in the production of gas by the person producing the gas. These\npipelines are not subject to the regulations. The situation which your letter describes is that of\ngas being transported to the Gulf lease by another person. Those lines belonging to the other\nperson are subject to the reporting requirements down to the downstream end of the meter, or\nyour piping, since those lines are service lines which are transporting gas from a common source\nof supply to a customer meter or a customer's piping.\nThe pipelines on the downstream side of the meter, or the point where Gulf takes custody of the\ngas, going to your pumping unit prime-mover are not subject to the reporting requirements or the\nFederal gas pipeline safety standards, since they are not service lines as currently defined.\nI trust that this has responded to your particular question. If we can be of further assistance,\nplease let us know.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n1\n\n<<<PAGE 2>>>\n\nGulf Oil Company - U.S.\nApril 11, 1974\nCERTIFIED MAIL\nMr. Edward F. Cygan\nDepartment of Transportation\nOffice of Pipeline Safety\nWashington, D.C. 20590\nGentlemen:\nWe have been requested by our Houston office to furnish you the attached duplicate\ncopies of Department of Transportation Form DOT F 7100.2-1 Annual Report for Calendar Year\n1973 covering operations in the States of Kansas and Oklahoma. Duplicated on each letter of\ntransmittal is a copy of the Certified Mail receipt stamped by Margaret V. Cooper acknowledging\nreceipt of the report.\nDuring a conversation between Mrs. F.I. Pointer and Mr. Cesar DeLeon of your office\nand Mr. R.O. Bobo regarding the reports, the question arose whether the lines were actually\nsubject to the reporting requirements contained in Part 191 of Title 49 of the Code of Federal\nRegulations.\nConfirming this discussion, in the State of Oklahoma, the lines involved serve several\nGulf leases in a non-rural area. Low pressure residue gas (8-12 psig) is purchased from Phillips\nPetroleum Company. Custody of the gas is taken at Gulf lease line connections and is delivered\nthrough Gulf owned short segments of line to pumping unit prime movers and oil treating heaters\non the lease.\nIn the State of Kansas, similar conditions exist. The low pressure fuel lines reported\nserve several Gulf leases in a non-rural area. Low pressure gas is purchased from Gas Service\nCompany and delivered through Gulf owned short segments of line to operate lease equipment.\nBased on this information, Mr. DeLeon advised that future filing of reports for these lines\nwould not be required. For\n2\n\n<<<PAGE 3>>>\n\nrecord purposes, we would appreciate confirmation of this decision.\nPlease advise if we may be of further assistance to you in this matter.\nYours very truly,\nT.W. Kidd\n3","truncated":false,"body_characters":3772}