{"operation":"document","citation":"PI-81-002","title":"James L. Stanton — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1981-02-24","effective_on":null,"summary":"PI-81-002 concerning 192.11.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1981/PI81002.pdf","body":"<<<PAGE 1>>>\n\nFEB 24 1981\nJames L. Stanton, Esq.\n517 1/2 North Main Street\nCarroll, Iowa 51401\nDear Mr. Stanton:\nThis is in response to your recent letter as well as to your telephone conversation\nwith Mr. Langley of our staff.\nGas pipeline safety standards are in 49 CFR Part 192. Section 192.11 governs\npetroleum gas systems. When a petroleum gas system, such as you describe, has\nfewer than 10 customers and no portion of the system is in a public place, it is not\nsubject to the requirements of Part 192 nor the industry standards (National Fire\nProtection Association standards No. 58 and No. 59) referenced in section 192.11.\nAlso, we have previously interpreted section 192.11 as not applying to single-tank-\nsingle-customer systems located on the customer's property, even though the system\nmay cross part of the customer's property that is a public place.\nAlthough it appears that Federal regulations do not apply, there may be Iowa State\nregulations, as Mr. Langley pointed out in your telephone conversation, that do\napply.\nA copy of Part 192, which you requested, is enclosed.\nSincerely,\nMelvin A. Judah\nActing Associate Director\nPipeline Safety Regulation\nMaterials Transportation Bureau\nJAMES L. STANTON\nH:\\INTERPRETATIONS\\192\\11\\91-02-24.doc\n1\n\n<<<PAGE 2>>>\n\nATTORNEY AT LAW\n517 ? NORTH MAIN STREET\nCARROLL, IOWA 51401\n????\nPHONE 712-792-9288\nDecember 29, 1980\nU. S. Department of Transportation\nResearch & Special Programs Admin.\nWashington, D. C. 20590\nRequest for Information-Natural Gas Pipeline Act of 1968\nGreetings:\nPresently I am involved in trying to resolve a dispute over the installation of a replacement gas\npipeline from an LP gas tank located on the same property in which my client installed the gas\nline from the LP tank to a building located on the same property. While I doubt very much that\nany federal regulation applies to this project since we are not dealing with \"interstate commerce\",\nI am advised that there might be certain federal regulations which might be applicable. In\nparticular, I would like to have a copy of the regulations of the office of the Secretary of\nTransportation, (49 CFR Part 192).\nI would appreciate your sending me copies of the above regulations and any other documents or\nregulations which, in your opinion, might be applicable to the above situation. As I stated above,\nI do not see how the federal regulations would cover a purely \"in house\" project in which the\nsource of gas (LP tank) and the facility using the gas are connected by a pipeline all of which is\non the owner's property. Your comments in this regard would also be appreciated.\nVery truly yours,\nJLS/mb James L. Stanton\n(See sketch over)\nOPSO Advisory Bulletin No. 76-6 June 1976 page 4\n. . . Details of the cost and the list of the 37 examination cities may be obtained from the AWS. Application closing date for the\nfirst round of examinations is August 15th. For a free copy of the Guide to AWS Welding Inspector Qualification and\nH:\\INTERPRETATIONS\\192\\11\\91-02-24.doc\n2\n\n<<<PAGE 3>>>\n\nCertification with application form, contact the Qualification-Certification Manager in Miami: American Welding Society,\n2501 Northwest 7th Street, Miami, Florida 33125, telephone (305) 642-7090.\nTHE READING RACK . . . Technical information relating to pipeline safety appears in the following industry publications (Note--copies\nof these articles are not available from OPSO, and inclusion here does not necessarily indicate that content is consistent with\ncurrent Federal regulations).\nGAS INDUSTRIES, Natural Gas Edition, April 1976, \"The OPSO Odorization Requirements for Gas in Transmission Lines,\"\nStaff Report; May 1976, \"Reminder Issued by OPSO on Corrosion Control Deadlines,\" Cesar DeLeon, Office of Pipeline\nSafety Operations; \"Conclusions Announced in Study of Plastic Pipe Use,\" Jack W. Pierce, formerly with Toups Corp.\nGAS DIGEST, March 1976, \"Monitoring Cathodic Protection of Isolated Services,\" George Hendrick, Southern California\nGas Co.; \"Intermountain Gas Updates System Odorization Operations,\" Oscar Kash, Intermountain Gas Co.\nEXCAVATING CONTRACTOR, May 1976, \"Utility Alert Networks,\" Staff Report.\nPIPELINE AND UNDERGROUND UTILITIES CONSTRUCTION, April 1976, \"Miss Dig Program Now Covers Upper\nMichigan,\" Staff Report.\nPIPELINE & GAS JOURNAL, May 1976, \"Put Corrosion Control in Your Design Plans,\" William McGary, Henkels &\nMcCoy, Inc.\nPIPE LINE INDUSTRY, May 1976, \"Status of Automatic Welding for Onshore/Offshore Lines, Part 1,\" Harry C. Cotton, The\nBritish Petroleum Co. Ltd.\nOIL & GAS JOURNAL, May 10, 1976, \"Improved Pipeline Coatings Emerge,\" J. R. Hancock, H. C. Price Co.; \"Pipelining\nPlunges Into Deeper Water,\" Staff Report.\nINTERPRETATION OF REGULATIONS\nRelates\nto 49 CFR,\n§192.3\nQuestion: Under the Natural Gas Pipeline Safety Act of 1968, at what point in a propane air peak-shaving facility does\njurisdiction begin?\nOPSO Interpretation: . . . \"In a propane air peak-shaving facility, liquid propane is vaporized and mixed with air to supplement\nnatural gas supplies during peak shaving. All 'pipeline facilities' are within the jurisdiction of the Act. 'Pipeline facilities' are\ndefined in the Act to include 'without limitation . . . any equipment, facility, or building used in the transportation of gas or the\ntreatment of gas during the course of transportation' (49 USC 1671 (4)). Peak-shaving facilities are an interrelated and often\nessential part of a gas distribution system and fall within the intended coverage of the term 'pipeline facilities.' Consequently, a\npropane air peak-shaving facility is in its entirety subject to the jurisdiction of the Act.\"\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nThe Secretary of Transportation has determined that publication of this periodical is necessary in the transaction of the public\nbusiness required by law of this Department. Use of funds for printing this periodical has been approved by the Director of the\nOffice of Management and Budget through November 30, 1976.\nH:\\INTERPRETATIONS\\192\\11\\91-02-24.doc\n3","truncated":false,"body_characters":6056}