State of New York — Pipeline Safety Interpretation

Page 1July 8, 1975 Mr. Robert L. Swartwout Energy Division-Gas State of New York Public Service Commission 44 Holland Avenue Albany, New York 12208 Dear Mr. Swartwout: This refers to your letter of June 20, 1975, concerning the proper classification under 49 CFR Part 192 of 6.16 miles of coated gas pipelines running from interstate transmission lines to distribution centers. You ask whether the connection of service lines to the pipelines causes them to be distribution facilities under Part 192. Under Section 192.3, the term "distribution line" is defined as "a pipeline other than a gathering or transmission line." by this definition, a pipeline is classified as a "distribution line" only if it is not a gathering line or a transmission line, irrespective of whether service lines are connected to the pipeline. We are in agreement, I believe, that none of the 6.16 malls of pipelines is a "gathering line" as that term is defined in Section 192.3. Therefore, unless it can be reasonably shown that the pipelines are not transmission lines within the meaning of the term "transmission line" in Section 192.3, they are not properly classified as "distribution lines." As we stated in our letter of May 30, 1975, on this subject, the pipelines appear to us as lateral transmission lines. Assuming this is true, we expect that the Commission will revise its March 18 Order to make it apply to 49 CFR 192.457 in addition to the State requirements. Please advise us what action the Commission plans to take. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations dal\192\457\75-07-08 1#

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