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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-71-046 ([American Petroleum Institute] [B. H. Lord])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: American Petroleum Institute

Individual Name: B. H. Lord

Location State: DC Country: US

View the Interpretation Document

Response text:

Mr. B. H. Lord, Director
Division of Transportation
American Petroleum Institute
1801 K Street, N. W.
Washington, D. C. 20006

Dear Mr. Lord:

This is in reply to the petition for reconsideration filed by the American Petroleum Institute on
October 26, 1970. That part of the petition which requested the inclusion of API Standard 6A in
Section 192.145(a) of the Minimum Federal Safety Standards, was favorably acted upon by the
spot amendment, issued on November 10, 1970. However, no action has been taken on the
request for modification of Section 192.615(d), which requires that each operator shall establish
an educational program to enable customers and the general public to recognize and report a gas
emergency to the appropriate officials.

No change in Section 192.615(d) is contemplated at this time. In our view, the objections of the
American Petroleum Institute are not sufficient, since the language of this Section is sufficiently
general to allow for the operational differences between gathering lines, transmission companies
and distributors. The nature of the "educational program to enable customers and the general
public to recognize and report a gas emergency to the appropriate officials" is not specified, and
may, of course, vary according to the circumstances of the individual operator. What is intended
is that ledge of how to recognize a possible gas emergency and what authority to notify promptly.

It was certainly not intended, as suggested in the petition, that "a gatherer with a few miles of
jurisdictional gathering lines would be required to spend the same amount of money and effort as
would a large transmission company or distribution company with thousands of miles
jurisdictional lines."

Although the customers of gathering lines are, as argued in the petition, usually transmission
companies, that is not always the case, the moreover, even on gathering lines emergencies may
occur which effect the public as well as customers. For that reason, the request that operators of
natural gas gathering lines be exempted from the requirements of Section 192.615(d) is denied.
We agree, however, with your suggestion that the efforts of each operator shall be related to the
size of his operations, and that the required educational programs may be organized and carried
out by the operators jointly through trade associations representing the various segments of the
natural gas pipeline industry, cooperating with each other to avoid "duplication of effort" and
conflicting instructions.

We hope this answers all your requests for clarification, and if we can be of further assistance,
please let us know.


Joseph C. Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.145 Valves