Interpretation Response #PI-76-005

Interpretation Response Details

January 27, 1976

Mr. Anthony Creston
Chief, Pipeline Safety
Arkansas Public Service Commission
State Capitol
Justice Building
Little Rock, Arkansas 72201

Dear Mr. Creston:

This refers to your letter of November 10, 1975, requesting guidance on interpretations concerning the Federal gas pipeline safety standards. Your comments have been structured into a question and answer format for clarification purposes.

Question: Under Section 192.709 of Title 49 of the Code of Federal Regulations (49 CFR), is the operator of a transmission system required to make only those transmission line records that have been generated since the adoption of the Federal standards available to inspection officials?

Answer: As a certified State agency, the Arkansas Commission may inspect and copy any records of a pipeline operator as necessary for purposes of enforcing these standards. These records include not only those required by Section 192.709 but also pertinent records which an operator voluntarily maintains.

Question: Is an operator of a transmission gas pipeline system that supplies gas to a customer responsible for overpressure protection of the customer's pipeline or facilities from the point of gas sale?

Answer: One principle expressed in the definition of the term "service line" is that an operator engages in the transportation of gas to a customer to the first point at which both the sale and delivery of gas to the customer have occurred. Likewise, when gas is sold to a customer who is a distribution operator, the transmission operator engages in the transportation of gas, and thus is responsible for compliance with Part 192 regarding pipelines used in that transportation, to the first point at which sale and delivery of the gas have both occurred. Gas is delivered to a customer when it enters the customer's pipeline.

Therefore, a transmission operator is not responsible for compliance with Part 192 regarding a distribution operator's pipeline downstream from the point of sale.

Thank you for your cooperation in matters of pipeline safety.

Sincerely,

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections