{"operation":"document","citation":"PI-75-025","title":"State of New York — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-05-30","effective_on":null,"summary":"PI-75-025 response to State of New York concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-025.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-025.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-025","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75025.pdf","body":"<<<PAGE 1>>>\n\nMay 30, 1975\nMr. Robert L. Swartwout\nEnergy Division-Gas\nState of New York\nPublic Service Commission\n44 Holland Avenue\nAlbany, New York 12208\nDear Mr. Swartwout:\nThis letter refers to the 6.16 miles of coated gas pipelines for which the Commission by order\ndated March 18, 1975, granted the National Fuel Gas Distribution Corporation a waiver from\ncompliance with a State requirements that all transmission lines be cathodically protected by\nAugust 1, 1974. The waiver extended the deadline for compliance until November 1, 1975.\nIn our letter of April 15, 1975, we asked if the pipelines fall within the definition of \"transmission\nliens\" under 49 CFR 192.3, even though they operate at less than 20 percent of specified\nminimum yield strength. Because the waiver does not apply to Federal standards, this question is\nrelevant to whether the pipelines are in violation of the August 1, 1974, deadline for cathodic\nprotection of effectively coated transmission lines under 49 CFR 192.457.\nYour response, dated May 1, 1975, states your conclusion that the pipelines, which stem from\ninterstate transmission lines and run to regulator stations supplying distribution systems, are\nclassified as \"distribution lines\" under 49 CFR 192.3. You apparently reach this conclusion\nbecause the interstate liens are not gathering lines or storage facilities within the meaning of clause\n(1) of the definition of \"transmission line\" in 49 CFR 192.3, which reads:\n\"'Transmission line' means a pipelines, other then a gathering line, that - (1) Transports gas\nfrom a gathering line or storage facility to a distribution center or storage facility.\"\nIt appears to us, however, based on the information you have provided, that the 6.16 miles of\npipelines are lateral extensions of interstate transmission lines which serve distribution centers.\nWhen viewed in this respect, the beginnings of these lines are not the interstate lines, themselves,\nbut the sources of the interstate lines. If these sources are gathering lines or storage facilities,\nthen the 6.16 miles of pipelines would fit the definition of transmission line.\nAlso for purposes of classification under 49 CFR Part 192, a \"distribution line\" is either a main or\na service line. By definition in 49 CFR 192.3, a main is a source of supply for service lines.\nBecause there is no indication that the 6.16 miles of pipelines are service lines or have services\nconnected to them, we are further unable to agree that the pipelines are distribution lines.\ndal\\192\\457\\75-05-30\n1\n\n<<<PAGE 2>>>\n\nBased on our comments, we would appreciate your advising whether or not it is still your opinion\nthat the 6.16 miles of pipelines are distribution lines under 49 CFR Part 192 and giving us your\nreasons. If not, does the Commission intend to revise the March 18 order to make it applicable to\n49 CFR 192.457?\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\457\\75-05-30\n2","truncated":false,"body_characters":2944}