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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-85-011 ([Streich, Lang, Weeks & Cardon] [James A. Ryan])

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

Interpretation Response Details

Response Publish Date:

Company Name: Streich, Lang, Weeks & Cardon

Individual Name: James A. Ryan

Location State: AZ Country: US

View the Interpretation Document

Response text:

Mr. James A. Ryan

Streich, Lang, Weeks & Cardon

2100 First Interstate Bank Plaza

Post Office Box 471

Phoenix, Arizona 85001 Dear Mr. Ryan:

Your letter of January 31, 1985, describes two situations concerning natural gas service lines and asks several questions about the application of 49 CFR Part 192 to those situations.

Your "Situation One" involves a portion of a gas distribution system where mains and services were installed to supply natural gas to houses but the services were never used. These services were pressurized by the natural gas mains to which they were connected. You then ask five questions to which we respond as follows:

Question 1: At the time they were installed in the early 1970's, were the service lines "new service lines" within the meaning and intent of 49 C.F.R. Section 192.727?

Response: New services are not addressed in §192.727. Section 192.379, New service lines not in use, would be one of the applicable requirements if the service lines were readied for service after March 12, 1971 (see §192.13(a)).

Question 2: At the time they were installed in the early 1970's, were the service lines "deactivated" lines within the meaning and intent of 49 C.F.R. Section 192.727?

Response: In the natural gas distribution business an active service is one that is supplying gas to a customer. To be "deactivated" a line must first have been activated. Since these service lines never supplied natural gas to a customer and, thus had not been activated, they could not be considered "deactivated" within the meaning and intent of §192.727.

Question 3: At the time they were installed in the early 1970's were the service lines "abandoned" lines within the meaning and intent of 49 C.F.R. Section 192.727?

Response: Within 49 CFR Part 192 we rely upon the dictionary definitions of words unless they are defined within the part. Webster Third New international Dictionary defines the word "abandoned" as "to cease to assert or exercise an interest, right or title to, especially with intent to never again resume or reasserting it." Since the service lines remained pressurized by natural gas from the distribution main, it appears that the operator continued to assert or exercise an interest in these service lines. Thus, they were not abandoned with the meaning and intent of §192.727.

Question 4: As of September 26, 1984, was the leaking service line an "abandoned" line within the meaning and intent of 49 C.F.R. Section 192.727?

Response: No. See #3 above.

Questions 5: On the facts provided above, was the Gas Company in violation of any of the provisions of 49 C.F.R. Section 192? If so, please identify those provisions and the nature of the violation.

Response: There is inadequate information provided in your letter to determine any violation. The operator would be required to meet all applicable requirements of Part 192 with regard to maintenance, operations, surveillance, pressure control, leak surveys, odorization, etc. Possible violations of these standards would be determined by the Office of Operations and Enforcement, Materials Transportation Bureau, or the State agency with safety jurisdiction over an intrastate line.

"Situation Two" describes a gas service line that had discontinued supplying natural gas to a customer. Such a service would be required to meet the requirements of §192.727(d). You asked two questions concerning this example to which we respond as follows:

Question 1: As of September 15, 1981, was the leaking service line an "abandoned" line within the meaning and intent of 49 C.F.R. Section 192.717?

Response: This service line would not be "abandoned" within the meaning and intent of §192.727 since it is still pressurized by natural gas and intended for future use, although service to the customer had been discontinued, according to your letter.

Question 2: On the facts provided above, was the Gas Company in violation of any of the provisions of 49 C.F.R. Section 192 as of September 15, 1981? If so, please identify those provisions and the nature of the violation.

Response: There is inadequate information given to determine if there is a violation. Possible violations of these standards would be determined by the Office of Operations ad Enforcement, Materials Transportation Bureau, or the State agency with safety jurisdiction over an intrastate line.

We hope that this has satisfactorily answered your concerns.

Sincerely,

Richard L. Beam

Associate Director for

Pipeline Safety Regulation

Materials Transportation Bureau

Regulation Sections

Section Subject
192.379 New service lines not in use