{"operation":"document","citation":"PI-76-064","title":"Union Real Estate Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-09-20","effective_on":null,"summary":"PI-76-064 response to Union Real Estate Company concerning 192.453.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-064.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-064.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-064","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76064.pdf","body":"<<<PAGE 1>>>\n\nSeptember 20, 1976\nMs. Victoria Bandi\nUnion Real Estate Company\n428 Forbes Avenue\nPittsburgh, Pennsylvania 15219\nDear Ms. Bandi:\nThis is in reply to the questions posed in your letter of August 31, 1976.\nQuestion 1: Is an underground gas line from the curb to an existing apartment building required\nto be tested by a cathodic engineer?\nAnswer: Presuming that the gas line is used in the distribution of gas subject to the jurisdiction\nof the Federal gas pipeline safety standards in 49 CFR Part 192, it must be tested in accordance\nwith Section 192.465. Also, if the line was installed before August 1, 1971, Section 192.457(b)\nrequires that the line be electrically surveyed for active corrosion. Section 192.453 requires that\nthe survey and tests be performed or directed by a person qualified by experience or training in\ncorrosion control methods. The term \"cathodic engineer\" is not used in the Federal standards.\nQuestion 2: If so, whose responsibility would it be to make such test; the supplying gas\ncompany or the owner of the apartment building?\nAnswer: The \"operator\" of the line as defined is Section 192.3 would be responsible for making\nthe test. Since your letter does not contain information about the disposition of the gas\ntransported in the pipeline, who owns the pipeline, and the location of all meters involved, we are\nunable to tell which person is the \"operator.\"\nQuestion 3: If such test is required, when is such test to be made?\nAnswer: standards.\nThe various time requirements as appropriate are set out in the applicable safety\nJT\nC:\\WP51\\192\\457\\76-09-20\n1\n\n<<<PAGE 2>>>\n\nWe have enclosed a copy of the Natural Gas Pipeline Safety Act of 1968 and the Federal\nstandards.\nSincerely,\n\\signed\\\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nJT\nC:\\WP51\\192\\457\\76-09-20\n2\n\n<<<PAGE 3>>>\n\nUNION REAL ESTATE CO.\nAugust 31, 1976\nDirector\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nGood Morning,\nI would very much appreciate receiving a reply to the following questions as well as a copy of the\nAct and the Sections pertaining thereto:\n1. Is an underground gas line from the curb to an existing apartment building required to be\ntested by a cathodic engineer?\n2. If so, whose responsibility would it be to make such a test; the supplying gas company or\nthe owner of the apartment building?\n3. If such test is required, when is such test to be made?\nVery truly yours,\nUNION REAL ESTATE COMPANY\n\\signed\\ _\nVictoria Bandi\nJT\nC:\\WP51\\192\\457\\76-09-20\n3\n\n<<<PAGE 4>>>\n\nSeptember 18, 1976\nMr. Cesar DeLeon\nActing Director,\nOffice of Pipeline Safety Operations,\nDepartment of Transportation\nMaterials Transportation Bureau\nWashington, D.C. 20590\nDear Mr. DeLeon:\nWe have your kind letter of September 14, 1976 and can appreciate the reasons for not granting a\nwaiver at this time as requested by this company.\nWhile it is no excuse, frankly we did not know of the enactment of the Pipeline Safety Act for\nGas. As soon as we learned of it, we called almost every governmental office that could have\nbeen involved and no one seemed to know anything about this act. When we called the Gas\nCompany that serves our Trailer Park, we were also told that it knew nothing of this act.\nHowever, at a later date it told us that we should contact a Mr. Jack C. Overly, Chief Western\nRegion, Office of Pipeline Safety Operations at Burlingame, California. This we did at once.\nHe was most obliging and gave us the names of a few companies that could do the required\nsurvey and work and complete the prescribed forms. Since July 19, 1976 we were promised by a\nMr. James of Pacific Corrosion research Inc that the required work and form work would be done\nat once. This company is at 11934 South Hawthorne Boulevard, Hawthorne, California 90250.\nNumerous telephone calls to this company and Mr. James at 679-5842 brought no results but only\npromises to do the work. Now we have engaged a licensed and capable (we think) plumbing firm\nknown as Century Plumbing (I believe that is the name) and a Mr. Dennis Bailey in charge has\nexamined our trailer park and made (he said) five calls to your offices to proceed. We are sure he\nwill do the required work soon.\nWe want to comply fully at once. We are doing all we can. If you have someone who can do the\nwork sooner and forthwith, let us know. Mr. Bailey promises to get it done now and he is buying\ncertain meters for the work.\nJT\nC:\\WP51\\192\\457\\76-09-20\n4\n\n<<<PAGE 5>>>\n\nWe will keep to touch. As a former (sometime) governmental agency associate I know what it is\nto respond to all requirements.\nSincerely yours,\n\\signed\\\nJT\nC:\\WP51\\192\\457\\76-09-20\n5","truncated":false,"body_characters":4694}