{"operation":"document","citation":"PI-96-005","title":"Utah Department of Commerce Division of Public Utilities — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-03-07","effective_on":null,"summary":"PI-96-005 response to Utah Department of Commerce Division of Public Utilities concerning 192.11.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96005.pdf","body":"<<<PAGE 1>>>\n\nMAR - 7 1996\nRussell W. Copeland\nPipeline Safety Supervisor\nUtah Department of Commerce\nDivision of Public Utilities\nPO Box 45807\nSalt Lake City, Utah 84145-0807\nDear Mr. Copeland:\nI have considered the liquefied petroleum gas (LPG) distribution systems described\nin your letter of January 17, 1996. In these systems, the LPG storage tank is owned\nand maintained by an LPG distributor while the associated gas distribution piping is\nowned and maintained by a separate business owner.\nAs you know, any person who owns or operates a gas pipeline facility that comes\nunder Part 192 is an operator responsible for compliance with Part 192. And, under\n§ 192.11, an LPG distribution system includes both the tank and associated\ndistribution piping.\nThus, I concur that as a tank owner, the LPG distributor may be cited for violations\ninvolving the tank. Also, as a piping owner, the separate business owner may be\ncited for violations involving the distribution piping. But, in our experience, a\ncompliance action is more effective when it focusses [sic] on the person who actually\noperates the facilities concerned. Your letter did not mention who operates, rather\nthan who owns or maintains, the tank and associated piping. Assuming the separate\nbusiness owner operates these facilities together, we would recommend enforcing all\napplicable regulations against the separate business owner, although the LPG\ndistributor owns and maintains the tank.\nSincerely,\nCesar De Leon\nDeputy Associate Administrator for Pipeline Safety\n05/10/99 H:\\INTERPRETATIONS\\192\\11\\96-03-07.doc","truncated":false,"body_characters":1581}