{"operation":"document","citation":"PI-74-0145","title":"Mr. John Searcy — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-11-06","effective_on":null,"summary":"PI-74-0145 response to Mr. John Searcy concerning 192.603.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0145.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0145.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0145","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-11-06_Searcy_192.603%20-%20lmxs.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0145\nNovember 6, 1974\nMr. John Searcy\nEngineering Division\nTennessee Public Service Commission\nCordell Hull building\nNashville, TN 37219\nDear Mr. Searcy:\nThis refers to your letter of October 2, 1974, in which you ask whether an entire distribution\nsystem is a district for the purpose of 49 CFR 192.741(a).\nThis rule provides:\n(a) \"Each distribution system supplied by more than one district pressure regulating\nstation must be equipped with telemetering or recording pressure gages to indicate the gas\npressure in the district.\"\nSection 102.741(a) applies where two or more district pressure regulators are used in supplying\ngas to a distribution system downstream from the regulators. In this case, the distribution system\ncomprises two or more districts served by the regulators; and the system must be equipped with\ntelemetering or recording pressure gages to show the gas pressure in each district.\nIn answer to your other questions, first it is not mandatory that an operator include material\nwhich we present in industry seminars in an operating and maintenance plan under section\n192.603(b). The material is presented merely as a guide to operators. Secondly, where a single\noperator and maintenance plan may suffice for running all of the systems. However, any\npeculiarities in a system must be covered as required by Part 192 in the operator's plan, either in\nthe single plan or in a separate plan.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n*\n\n<<<PAGE 2>>>\n\nOctober 2, 1974\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\n2100 Second Street, SW\nWashington, D.C. 20590\nDear Mr. Caldwell:\n192.741(a) requires that \"Each distribution system supplied by more than one (1) district pressure\nregulating station . . . be equipped with telemetering or recording pressure gauges...\" this implies\nthat an entire distribution system is a district for the purpose of this regulation. Is this a correct\ninterpretation?\n192.603(b) requires a written operating and maintenance plan and that records be kept to\nadminister the plan. The material used for the DOT Industry Seminar on Safety Requirements\noutlines on Page 20, Unit B-5, Paragraph 1.d., eight (8) items which the plan should include. It is\na correct interpretation that it is mandatory that these items, particularly odorization equipment,\nbe included in an operation and maintenance plan? Where one (1) utility operates gas systems in\nmore than one (1) city or town, are operation and maintenance plans and records required at each\nsystem?\nSincerely,\nJohn Searcy\nEngineering Division","truncated":false,"body_characters":2624}