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Interpretation Response #PI-73-011 ([Perry Gas Department] [Russell W. Itschner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Perry Gas Department

Individual Name: Russell W. Itschner

Location State: MI Country: US

View the Interpretation Document

Response text:

May 12, 1973

Mr. Russell W. Itschner
Superintendent
Perry Gas Department
Perry, Missouri 39213

Dear Mr. Itschner:

This is in response to your letter dated April 25, 1973, regarding your failure to file an inspection
and maintenance plan with our Office pursuant to Section 192.17, 49 CFR.

We do not have a form that you are required to fill out to comply with this regulation. The inspection and maintenance plan is a plan formulated by the gas operator, such as yourself, to be used in inspecting and maintaining your pipeline facilities. The plan should include the pertinent parts of Subpart I — Requirements for Corrosion Control, Subpart L — Operations and Subpart M — Maintenance of Part 192, 49 CFR, as well as other parts of Part 192 which would be required to properly operate and maintain your pipeline facilities.

The plan should be an instruction type manual specifying the operating and maintenance procedures which must be followed by the operator to assure the safe operation of the gas distribution system. The plan should incorporate inspection and maintenance procedures for at least the following items:

  1. Distribution valves
  2. Pressure Limiting and Regulating Stations
  3. Pressure Relief Valves
  4. Odorization Equipment
  5. Mains and Services (Leak Repairs)
  6. Customer Meters and Regulators
  7. Cathodic Protection System (if applicable)
  8. Leakage surveys
  9. Patrolling of Distribution System
  10. Surveillance of Distribution System
  11. Emergency Plans
  12. Investigation of Failures

Records should be available in gas operators office on the items mentioned above and the gas
operator should have maps of the system available if they are necessary for the implementation of
the inspection and maintenance plan. The Office of Pipeline Safety does not have a standard
format for an inspection and maintenance plan, and each operator may formulate the type of plan
which he feels will best suit his particular operation.

We trust that this has clarified this matter. Please submit an inspection and maintenance plan to us
as quickly as possible.

Sincerely,

Cesar DeLeon
Compliance Officer
Office of Pipeline Safety

Regulation Sections