{"operation":"document","citation":"PI-76-005","title":"Arkansas Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-01-27","effective_on":null,"summary":"PI-76-005 response to Arkansas Public Service Commission concerning 192.709.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76005.pdf","body":"<<<PAGE 1>>>\n\nJanuary 27, 1976\nMr. Anthony Creston\nChief, Pipeline Safety\nArkansas Public Service Commission\nState Capitol\nJustice Building\nLittle Rock, Arkansas 72201\nDear Mr. Creston:\nThis refers to your letter of November 10, 1975, requesting guidance on interpretations\nconcerning the Federal gas pipeline safety standards. Your comments have been structured into a\nquestion and answer format for clarification purposes.\nQuestion: Under Section 192.709 of Title 49 of the Code of Federal Regulations (49 CFR),\nis the operator of a transmission system required to make only those transmission\nline records that have been generated since the adoption of the Federal standards\navailable to inspection officials?\nAnswer: As a certified State agency, the Arkansas Commission may inspect and copy any\nrecords of a pipeline operator as necessary for purposes of enforcing these standards. These\nrecords include not only those required by Section 192.709 but also pertinent records which an\noperator voluntarily maintains.\nQuestion: Is an operator of a transmission gas pipeline system that supplies gas to a customer\nresponsible for overpressure protection of the customer's pipeline or facilities from\nthe point of gas sale?\nAnswer: One principle expressed in the definition of the term \"service line\" is that an operator\nengages in the transportation of gas to a customer to the first point at which both the sale and\ndelivery of gas to the customer have occurred. Likewise, when gas is sold to a customer who is a\ndistribution operator, the transmission operator engages in the transportation of gas, and thus is\nresponsible for compliance with Part 192 regarding pipelines used in that transportation, to the\nfirst point at which sale and delivery of the gas have both occurred. Gas is delivered to a\ncustomer when it enters the customer's pipeline.\ndal\\192\\709\\76-01-27\n1\n\n<<<PAGE 2>>>\n\nTherefore, a transmission operator is not responsible for compliance with Part 192 regarding a\ndistribution operator's pipeline downstream from the point of sale.\nThank you for your cooperation in matters of pipeline safety.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\709\\76-01-27\n2\n\n<<<PAGE 3>>>\n\nNovember 10, 1975\nMr. Robert F. Aubry\nChief, Southwest Region\nOffice of Pipeline Safety\nDepartment of Transportation\n6634 Hornwood Drive\nHouston, Texas 77036\nDear Mr. Aubry:\nReference telephone conversation between yourself and Cody Stuart regarding an inspection of\nTexas Eastern Transmission Corporations interstate transmission facilities in Arkansas. This\noperator interprets paragraph 192.709, Minimum Federal Safety Standards to require each\noperator to make only those transmission line records that have been generated since the adoption\nof the federal standards available to inspection officials. This interpretation is based upon\nparagraph 192.13(c) which requires each operator to follow the plans, procedures, and programs\nthey are required to establish under part 192.\nThis operator also contends the supplier of gas is not responsible for overpressure protection of a\ncustomers pipeline or facilities downstream from the point of gas sale. This interpretation is based\nupon paragraphs 192.619(a) and 192.621(a) which stipulate that no person may operate a pipeline\nor distribution system without establishing and maintaining a maximum allowable operating\npressure on each segment of pipeline. In essence, the operator contends an operator is\nresponsible for overpressure protection on those facilities the operator owns and operates. The\nservice contract this operator has with each customer provides for the minimum pressure required\nto maintain customer service and does not provide for the maximum allowable operating pressure.\nRequest your guidance on these interpretation [sic] and inform the Commission if an official\ninterpretation from Pipeline Safety, Department of Transportation, Washington, D.C. is required.\nSincerely,\nAnthony Creston\nChief, Pipeline Safety\ndal\\192\\709\\76-01-27\n3","truncated":false,"body_characters":4036}