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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-74-0126 ([Gulf Oil Company - U.S.] [Mr. T. W. Kidd])

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

Interpretation Response Details

Response Publish Date:

Company Name: Gulf Oil Company - U.S.

Individual Name: Mr. T. W. Kidd

Location State: OK Country: US

View the Interpretation Document

Response text:

Mr. T. W. Kidd

Gulf Oil Company - U.S.
Production Department
Oklahoma City District
600 Oklahoma Mortgage Building
Oklahoma City, OK  73102

Dear Mr. Kidd:

This responds to your letter of April 11, 1974, regarding the reporting of pipelines on Department of Transportation Form DOT F 7100.2-1 and your conversations by telephone with Mrs. Painter and Mr. DeLeon of our office.

Your letter indicates that in the State of Oklahoma, the lines involved serve several Gulf leases in a non-rural area.  Low pressure residue gas (8-12 psig) is purchased from Phillips Petroleum Company.  Custody of the gas is taken at Gulf lease line connections and is delivered through Gulf owned short segments of line to pumping unit prime movers and oil treating heaters on the lease.  You letter further indicates that similar conditions exist in Kansas.

The advice given to you by Mr. DeLeon was based on gas moving in pipelines within a production facility used solely in the production of gas by the person producing the gas.  These pipelines are not subject to the regulations.  The situation which your letter describes is that of gas being transported to the Gulf lease by another person.  Those lines belonging to the other person are subject to the reporting requirements down to the downstream end of the meter, or your piping, since those lines are service lines which are transporting gas from a common source of supply to a customer meter or a customer's piping.

The pipelines on the downstream side of the meter, or the point where Gulf takes custody of the gas, going to your pumping unit prime-mover are not subject to the reporting requirements or the Federal gas pipeline safety standards, since they are not service lines as currently defined.

I trust that this has responded to your particular question.  If we can be of further assistance, please let us know.


Joseph C. Caldwell
Office of Pipeline Safety

Regulation Sections

Section Subject
192.1 What is the scope of this part?