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Interpretation Response #PI-74-0108 ([Arizona Corporation Commission] [Mr.H. R. Garabrant])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arizona Corporation Commission

Individual Name: Mr.H. R. Garabrant

Location State: AZ Country: US

View the Interpretation Document

Response text:

April 22, 1974

Mr.H. R. Garabrant
Arizona Corporation Commission
Utilities Division
1688 West Adams
Phoenix, AR  85007

Dear Mr. Garabrant:

Thank you for you letter of April 10, 1974, asking whether the Federal Gas pipeline safety standards (49CFR Part 192) require leakage surveys in advance of scheduled street repairs.

As you point out, section 192.723 of the standards sets forth the requirements concerning leakage surveys.  This section requires surveys to be made periodically as provided in the operator's operating and maintenance plan but not less frequently than every year or every 5 years, depending on pipeline location.  The section does not specifically require surveys in advance of street construction.  However, if such surveys are prescribed in an operating and maintenance plan, then the operator concerned must conduct them.  The procedures of an operating and maintenance plan are as binding on the operator as the Federal standards (section 192.13(c)).

You enclosed a copy of the Arizona Public Service Company's operating and maintenance plan.  We have reviewed the plan, and it does not appear that any of its provisions would require a leakage survey in advance of street repairs.

Inasmuch as the Federal standards and the operating and maintenance plan do not require this type of survey, compliance action based on either the standards or the plan would be inappropriate.  However, if you feel that a leak survey should be required in advance of street repairs, we suggest that your Commission adopt standards more stringent than Federal standards for intrastate pipeline facilities.


                                                                        Joseph C. Caldwell
                                                                        Office of Pipeline Safety

Regulation Sections

Section Subject
192.13 What general requirements apply to pipelines regulated under this part?