{"operation":"document","citation":"PI-77-029","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-12-13","effective_on":null,"summary":"PI-77-029 response to Memo: Internal concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-029.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-029.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-029","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77029.pdf","body":"<<<PAGE 1>>>\n\nDecember 13, 1977\nMaster Meter Systems\nActing Director, Office of Pipeline\nSafety Operations, DMT-20\nChief, Western Region, DMT-215\nWith regard to your memo of November 29 concerning master meter operators, Buck Furrow and\nI have made some comments that should be incorporated in your letter and your \"Master Meter\nGas Systems\" write-up.\nCesar DeLeon\nAttachment\ndal\\192\\457\\77-12-13\n1\n\n<<<PAGE 2>>>\n\nMEMORANDUM\nNovember 29, 1977\nSUBJ: Master Meter Operators\nFROM: Chief, Western Regional Office\nTO: Acting Director, Office of Pipeline\nSafety Operations, DMT-20\nAttached is a copy of an article recently received operations for apartments.\nconcerning master meter\nPlease note the several misleading statements concerning the regulation and/or\nAct.\nUnfortunately articles such as this encourage non compliance by operators. The\nlast paragraph on the 1st page more or less sums up what master meter operators\nare doing here in California.\nI would like to reply to the publisher with a letter such as I have attached in draft\nform. Please comment.\nJack C. Overly\ndal\\192\\457\\77-12-13\n2\n\n<<<PAGE 3>>>\n\nDRAFT\nTo Editor, The Property Manager\n505 Shatto Place\nLos Angeles, California 90020\nDear Sirs:\nI have recently seen an article in your publication discussing the Natural Gas Pipeline Safety Act.\nI would like to clear up some discrepancies noted in the article.\nThe \"Natural Gas Pipeline Safety Act of 1968\" directed that standards were to be issued for\npipeline facilities used in the transportation of gas. The Act provides a civil penalty for persons in\nviolation of the regulation. The amount could be as much as $1,000 for each violation for each\nday the violation persists, except that the maximum penalty shall not exceed $200,000. In\ndetermining the amount of the penalty three items are considered.\n1. The size of the business of the person charged.\n2. The gravity of the violation.\n3. The good faith of the person charged in attempting to achieve compliance.\nAn interim standard was established in 1968. In 1970, Part 192, Regulations For The\nTransportation of Natural & Other Gas By Pipeline (Parts 191 & 192 Title 49 of the code of\nFederal Regulations) was established as minimum Federal safety standards & several Amendments\nhave been added since that time.\nThere are deadlines for compliance of some sections of the regulation. These were established to\nallow adequate time for existing systems to meet compliance requirements. These deadlines,\nhowever for the most part have expired.\nIt would be difficult to conclude that an operator is acting in \"good faith\" if, as is stated in the\narticle, \"owners will not comply with this law until they have been cited for non compliance\". The\npurpose of the regulation is not to \"hook\" gas operators but to promote public safety through\ndal\\192\\457\\77-12-13\n3\n\n<<<PAGE 4>>>\n\nadequate installation and operation of gas systems. By not meeting these minimum standards an\noperator may be ignoring conditions that could prove a hazard.\nI have included an attachment concerning master meter systems that may be of interest.\nThank you for your interest in gas safety.\nSincerely,\nJack C. Overly\ndal\\192\\457\\77-12-13\n4\n\n<<<PAGE 5>>>\n\nMr. Irving Thomsen\nApartment Association of L.A. County Inc.\n551 So. Oxford St.\nLos Angeles, CA July 12, 1977\nDear Mr. Thomsen:\nThis letter is in reference to our conversation of July 11, 1977. We will try to put into\nunderstandable terms, the National Pipeline Safety Act; and what our company does in relation to\ncompliance to that act.\nThe Law states that after the gas leaves the domain of the gas company, normally at the\nmaster meter, the responsibility of the gas and it's [sic] transportation to the individual reciepients\n[sic] becomes the responsibility of the property owner. Any gas lines that run underground must\nby the virtue of this law be Cathodically protected. This means that in order to eliminate the\npossibility of a gas explosion due to the pocketing of gas from a leak in the pipelines; the lines\nthemselves must be made more resistant to corrosion.\nOur company, by means of sacraficial [sic] annodization [sic] does what the law requirres\n(sic). We implant annodes [sic] under the ground and attach same to the gas lines which eliminate\nthe vast majority of corrosion. We also install dialectric [sic] unions on the lines and isolate the\nflow of gas to the individual entities. We do not disturb the interior of any building; nor do we\ndisrupt the landscape we work with. Any work we do is put in and all landscape is left as we\nfound it.\nWe do all inspections and testing free of charge. We submit written bids on any work that\nis needed to be in compliance with the Law. There are no deposits or pre-payments needed on\nany work we do. All work is paid for within 30 days after completion of all of our work. Any\nproperty that is in compliance with the law, we will send you certification of this for your\npermanent files. We also send certification of all work that is done to the proper authorities. All\nof our work is guaranteed for one full year from the date of completion. We also have additional\nguarantees available for extended periods, in incruments [sic] of one year each.\nIf there is any additional information we can supply you with, please let us know at your\nconvenience. We have enclosed some of our brochures for you, in the hope that they may answer\nany other questions that you might have.\nYours truly,\nAl D. Alexander\nNATIONAL PIPELINE SAFETY ACT OF\ndal\\192\\457\\77-12-13\n5\n\n<<<PAGE 6>>>\n\nPUBLIC LAW 90-481\n(Irving Thomsen, CPN, President Apartment Association of Los Angeles County has done some\nresearch for us on the National Pipeline Safety Act of Public Law 90-48l, 9th Congress, Sll66.\nHe submits the following for our information.)\nThe effective date of this Act is August 1, 1976. granted, making it effective August 1, 1977.\nHowever, as I read it, one year's grace was\nThe firms doing this type work, and I understand there are only one or two firms specializing in\nthis type installation in the Los Angeles area, usually install a dia-electric union wherever a gas\nline goes underground on the owner's side of the gas meter. This union is intended to prevent any\npipeline corrosion from spreading along the pipe above ground.\nThe firms also attach an almost pure magnesium block to the gas line at various locations to\nreduce the amount of corrosion. These blocks have to be serviced each year, at a cost of\napproximately 10 to 13% of the original cost.\nThe work required, as briefly presented above, is usually quite expensive. However, the life of the\npipes underground is reportedly extended two or three times it's [sic] original life by installing this\ncathodic protection.\nI'm enclosing a copy of a letter from a firm that does this type of work, along with a copy of the\nFederal rules and regulations relating to the pipeline safety act. The Public Law itself is available.\nI would guess most owners will not comply with this law until they have been cited for non-\ncompliance or the insurance companies require it. The owner will be \"hooked\" thereafter, so to\nspeak, in having this installation serviced each year.\n_\nTHE PROPERTY MANAGER\n_\nOfficial publication of the Property Management Division of the Realtors\nCalifornia Association of\nEditor: Posey Carpentier\nManaging Editor: Carolyn Angelos\ndal\\192\\457\\77-12-13\n6\n\n<<<PAGE 7>>>\n\nNormally, however, Federal and State enforcement efforts are primarily directed toward public\nutilities and to a lesser degree master meter operators.\nWhen a violation occurs, upon a proper showing in individual cases, the enforcing agency may\ndefer1 a decision on imposition of a penalty or other sanction while an owner executes an orderly\nprogram for compliance with the regulations. Notwithstanding this discretionary action, in the\nabsence of a statutory waiver, an owner would be legally subject to penalty for any operation\nwhich still contravene the regulations while the program is being conducted.\nIf it is later determined that an orderly program for compliance is not being conducted or if a\nsystem failure occurs requiring investigation, this office would take appropriate enforcement\naction.\n_\n1 to just \"defer\" the penalty means it will be imposed later; what we want to do is hold this\ndecision open.\ndal\\192\\457\\77-12-13\n7\n\n<<<PAGE 8>>>\n\nMASTER METER GAS SYSTEMS\nGenerally speaking, when gas is purchased at a master meter and then is distributed through\nunderground or exterior piping to others who consume the gas, the system is considered to be a\ngas distribution system.\nGas distribution systems are subject to Federal safety regulations under Natural Gas Pipeline\nSafety Act of 1968. (NGPSA).\nThe Federal regulations are called \"Regulations for the Transportation of Natural and Other Gas\nby Pipeline\". The regulations are published in Parts 191 and 192 of Title 49 of the Code of\nFederal Regulations.\nIndividual States may also regulate the safety of master meter gas distribution systems. Where\nthis is done, States enforce the Federal regulations and may have additional requirements. In\nStates that do not regulate master meter systems, enforcement is the direct responsibility of the\nOffice of Pipeline Safety Operations of the US DOT.\nMaster meter systems must comply with all applicable sections of the Federal regulations for gas\ndistribution systems. Sections of the regulations to which master meter operators should pay\nparticular attention are as follows:\n-191.5 - Telephonic notice of certain leaks\n-191.11 - Distribution System: Annual Report (DOT Form 7100.1-1)\n-192.17 - Inspection & Maintenance Plan\n-Subpart I - Requirements for Corrosion Control (192.451 through 192.491,\ninclusive)\n-192.605 - Essentials of Operating & Maintenance Plan\n-192.615 - Emergency Plans\n-192.723 - Distribution Systems: Leakage Surveys and Procedures.\nForms are not provided for records, reports, etc. other than those specifically identified in the\nRegulations.\nThe Federal regulations are enforced in an equal manner against all operators of master meter\nsystems.\ndal\\192\\457\\77-12-13\n8","truncated":false,"body_characters":10097}