{"operation":"document","citation":"PI-86-002","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1986-03-05","effective_on":null,"summary":"PI-86-002 response to Memo: Internal concerning 192.707, 192.721.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1986/PI86002.pdf","body":"<<<PAGE 1>>>\n\nDATE:March 5, 1986\nSUBJECT: ACTION: Answer to Questions in 49 CFR Part 192 contained in Memorandum of\nJanuary 13, 1986\nFROM: Lloyd W. Ulrich\nDirector, Alaska Natural Gas Pipeline Project, DPS-9\nTO: Richard Sanders\nManager, Pipeline Safety Division, DMA-607\nI have discussed your four questions with the Standards Division (DPS-11) and Enforcement\n(DPS-30) and following is our response:\nQuestion:\nThe first question deals with master meter operators and check meters. If a gas operator loans a\nmeter to a master meter operator to be used as a check meter in aiding the master meter operator\nfor a short period of time, does this extend the natural gas distribution operator's jurisdiction to\nthe outlet swivel of this check meter since the meter belongs to the distribution company?\nAnswer:\nNo. The act and standards in 49 CFR Part 192 apply to persons who own or operate pipeline\nfacilities. The distribution operator owns the loaned meter and would be responsible for ut under\nthe Act and standards. The distribution operator does not own or operate the master meter\nsystem and would not be responsible for any part of it other than the loaned meter.\nQuestion:\nIf a distribution company establishes a lease agreement for check meters and provides these\nmeters to a master meter operator, would this extend the distribution company's jurisdiction to the\noutlet swivel of the meter based on the service line definition?\nAnswer:\nThe arrangement is no different than in the first question except for the lease agreement. If any\nresponsibility lies with the distribution operator it's only for the meter. The lease may actually\nhave the effect of removing responsibility from the distribution operator.\nQuestion:\nWould pipeline working signs be required in close proximity of master meter facilities to meet\n192.707(c).\nAnswer:\nDB\nC:\\WP51\\INTERPRT\\192\\721\\86-03-05\n1\n\n<<<PAGE 2>>>\n\nUnder the regulations in section 192.707, master meter facilities are treated the same as other\nfacilities, there is no exemption for aboveground lines in a master meter system. The standards on\nline marking in section 192.707 apply equally to master meter facilities and distribution operator\nfacilities.\nQuestion:\nMany operators express concern in trying to meet DOT Code 192.721 -Distribution System:\npatrolling requirements. More specifically mains in places or on structures where anticipated\nphysical movement or external loading could cause failure or leakage must b be patrolled at\nintervals not exceeding 4½ months. This specific (b) section brings up several questions as to\nwhat areas should be patrolled on the 4½ months but at least four times each calendar year. It has\nbeen our practice in the past to indicate creek crossing exposed, bridge crossings or aerial\ncrossings, lines attached to buildings, or other structures where movement or loading could occur.\nQuite often operators disagree with our suggestions, and many feel this only is talking about aerial\ncrossings.\nAnswer:\nThe term \"in place\" would include buried pipeline facilities which goes beyond just aerial\ncrossings. Example of areas requiring the more frequent patrolling of section 192.721(b) would\nbe landslide areas, mine subsidence areas and areas susceptible to wash outs after a heavy rain.\nIn general, the places to be checked must be determined by each operator based on its knowledge\nof the characteristics and problem areas of the system. The places you mentioned could require\nfrequent patrol if it's reasonable to \"anticipate\" that movement or loading at those places could\ncause leaks or failure. The places an operator identifies, if any, should be noted in its O&M plan.\nDB\nC:\\WP51\\INTERPRT\\192\\721\\86-03-05\n2","truncated":false,"body_characters":3699}