{"operation":"document","citation":"PI-77-010","title":"James A. Long — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-03-28","effective_on":null,"summary":"PI-77-010 concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77010.pdf","body":"<<<PAGE 1>>>\n\nMarch 28, 1977\nMr. James A. Long\n12596 Lomica Drive\nSan Diego, California 92128\nDear Mr. Long:\nThank you for your letter of February 1, 1977, concerning the applicability of the Federal gas\npipeline safety standards (copy enclosed) to gas pipeline distribution systems in mobile home\nparks.\nThe standards are established under the Natural Gas Pipeline Safety Act of 1968 (the Act), and\napply to the gathering, transmission, and distribution of gas by pipeline. The Federal gas pipeline\nsafety standards have been available through the Office of Pipeline Safety Operations and various\npublic and industry organizations since they were enacted.\nGas pipelines in a mobile home park are covered by the Federal standards if they are used to\ndeliver gas to the persons who consume it, normally the tenants in the park.\nThis Office is responsible for enforcing compliance with the standards in California against\nsystems in mobile home parks which are not operated by public utilities. In order to maximize the\npublic benefit from our limited resources, however, our enforcement activities are primarily\ndirected toward the major systems under our jurisdiction and to a far lesser degree systems in\nmobile home parks.\nAt present we have under consideration a petition for rulemaking to exclude systems in mobile\nhome parks from the jurisdiction of the Federal standards because of alleged difficulties in\ncompliance. Our main concern is whether this proposal would have an adverse effect on public\nsafety. We do not yet have enough information to reach a conclusion and have requested the\nadvice of the Technical Pipeline Safety Standards Committee, a Federal Advisory Committee\nestablished under the Act.\nWe appreciate your concern in this matter.\nSincerely,\nJames T. Curtis, Jr.\nEnclosure\ndal\\192\\457\\77-03-28\n1\n\n<<<PAGE 2>>>\n\nMr. James A. Long\n12596 Lomica Drive\nSan Diego, California 92128\nDear Mr. Long:\nThank you for your letter of February 1, 1977, concerning the applicability of the Federal gas\npipeline safety standards (copy enclosed) to gas pipeline distribution systems in mobile home\nparks.\nThe standards are established under the Natural Gas Pipeline Safety Act of 1968 (the Act), and\napply to the gathering, transmission, and distribution of gas by pipeline. The Federal gas pipeline\nsafety standards have been available through the Office of Pipeline Safety Operations and various\npublic and industry organizations since they were enacted.\nGas pipeline in a mobile home park are covered by the Federal standards if they are used to\ndeliver gas to the persons who consume it, normally the tenants in the park.\nThis Office is responsible for enforcing compliance with the standards in California against\nsystems in mobile home parks which are not operated by public utilities. In order to maximize the\npublic benefit from our limited resources, however, our enforcement activities are primarily\ndirected toward the major systems under our jurisdiction and to a far lesser degree systems in\nmobile home parks.\nAt present we have under consideration a petition for rulemaking to exclude systems in mobile\nhome parks from the jurisdiction of the Federal standards because of alleged difficulties in\ncompliance. Our main concern is whether this proposal would have an adverse effect on public's\ninterest in pipeline safety. We do not yet have enough information to reach a conclusion and have\nrequested the advise of the Technical Pipeline Safety Standards Committee, a Federal Advisory\nCommittee established under the Act.\ndal\\192\\457\\77-03-28\n2\n\n<<<PAGE 3>>>\n\nTo whom it concerns:\nI just heard about the gas line protection act that was passed back in 1968. It is cathodic\nprotection to retard or prevent corrosion of gas pipe lines in the ground.\nI own a small mobile home park and I-(and other Park owners I have talked to) don't now\nif it applies to our pipes-or is it only for the major pipe lines thru [sic] out the country-\ntransporting gas under high pressure.\nPressure in mobile home parks is very low, and gas leakage (last line of hand written letter\ncannot be read) ... causing fires is mil. It costs quite a sum of money to have this work done, and\nthe money is perhaps for nothing.\nI would appreciate an answer to the question from one in authority.\nDoes this 1968 gas line protection law apply to mobile home parks???\nI await your reply as I have had no notice of any sort from any governmental agency. Perhaps\nbecause it does not apply?\nJames A. Long\n12596 Lomica Dr.\nSan Diego, California 92128\n_\nNo mobile home park has ever received any notice from any governmental ... (again, last line of\nletter cannot be read.)\ndal\\192\\457\\77-03-28\n3","truncated":false,"body_characters":4675}