Northern Arizona University — Pipeline Safety Interpretation

Page 1U.S. Department ofTransportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washington DC 20590 N OV 0 6 2017 Mr. Jonathan Heitzinger Associate Director: Utility Services Northern Arizona University PO Box 6016 Flagstaff, AZ 86011-6016 Dear Mr. Heitzinger: In a July 20, 2017 email to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 191. Specifically, you requested an interpretation on the requirements of§ 191.3 as it relates to a master meter system. You described your pipeline system as follows: Northern Arizona University currently operates as a Master Meter System. We purchase natural gas from Unisource Energy Services through four master meters and distribute natural gas through our internally owned and operated distribution system to buildings within our property line. Currently the piping systems total 42,467 feet in length, at pressures ranging from 10 to 54 psi, serving 112 risers with 5 pressure reducing stations and are not interconnected. The buildings are owned and operated by NAU, owned by NAU with portions rented to external entities, or have land leased to external organizations where they own and operate the buildings to support the primary mission of the university. The external organizations include retail, food service, laboratories, offices, and student housing and are charged for natural gas consumption through meters or rent. Upon review of interpretations PI-03-0101 and PI-73-030 it seems that a college or university is classified as a master meter system ifthere is underground piping and there are instances where the college or university is not the ultimate consumer. Additionally, there did not appear to be a limit to the size of systems, number of systems, or varying types of concessionaires or tenants. Based on the interpretations and regulations it seems that the Master Meter System definition does apply to NAU, and that our system is subject to the distribution regulations from 192-199 with the exceptions identified for a Master Meter System. You asked whether the Northern Arizona University (NAU) falls under the Master Meter System definition of 49 CFR 191.3 and could operate the pipeline system under the exceptions for a master meter system. Specifically, you asked for clarification of whether the definition of a Master Meter System is limited by size or by the number of types of services. The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 22 Section 191.3 defines a master meter system as: [A] pipeline system for distributing gas within, but not limited to, a definable area, such as a mobile home park, housing project, or apartment complex, where the operator purchases metered gas from an outside source for resale through a gas distribution pipeline system. The gas distribution pipeline system supplies the ultimate consumer who either purchases the gas directly through a meter or by other means, such as by rents. In PI-73-030, PHMSA stated that "If the college owned gas system provides gas to consumers such as concessionaires, tenants, or others, it is engaged in the distribution of gas, and the persons to whom it is providing gas would be considered the customers even though they may not be individually metered. In this situation the pipelines downstream of the master meter used to distribute the gas to these ultimate consumers would be considered mains and service lines subject to the Federal pipeline safety standards." (Collins Interpretation, PI-73-030, issued Oct. 24, 1973). In PI-03-0101, PHMSA explained that a college would not meet the definition of Master Meter System if it were only "using the gas delivered through its pipeline system to provide heat and hot water to campus buildings." In that instance "the college would be the consumer of the gas." It continued to explain, however, that ifthe college "gas system provides gas to consumers, such as concessionaires, tenants, or others, it is engaged in the distribution of gas, and the persons to whom it is providing gas would be considered the customers even though they may not be individually metered. In this situation, the pipelines downstream of the master meter used to distribute the gas to these ultimate consumers would be considered mains and service lines subject to the Federal pipeline safety regulations." In conclusion, the college would be considered a master meter system subject to the pipeline safety regulations if it provides gas to customers in addition to providing heat and hot water to campus buildings. (Bryant College Interpretation, PI03-0101, issued Feb. 14, 2003). The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 33 You have indicated that NAU's system is within the university's property line and distributes gas to buildings that are "owned and operated by NAU, owned by NAU with portions rented to external entities, or have land leased to external organizations where they own and operate the buildings to support the primary mission of the university. The external organizations include retail, food service, laboratories, offices, and student housing and are charged for natural gas consumption through meters or rent." NAU's gas distribution pipeline system therefore "supplies the ultimate consumer who either purchases the gas directly through a meter or by other means, such as by rents." Consequently, it meets the definition of a master meter system and NAU operates the pipeline system as a master meter system operator. Ifwe can be of further assistance, please contaCt Tewabe Asebe at 202-366-5523. Sincerely, Director, Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current applipation of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 4NORTHERN ARIZONA rm1 Facility Services PO Box 6016 Flagstaff, AZ 86011-6016 http://www. nau .edu/facility-services 928-523-6895 928-523-9481 fax Jon. Heitzinger@nau.edu U NI VE RS I T Y~ U.S Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2 nd Floor Mail Stop: E24-455 1200 New Jersey Avenue, SE, Mail Stop: E24-455 Washington, DC 20590 Dear Sir/ Madam, I am writing you to determine if Northern Arizona University (NAU) falls under the Master Meter System definition from Title 49 CFR 191.3 and should operate our distribution system under the exceptions for a master meter system under CFR 191-199. Specifically, I am seeking clarification of whether the definition of a Master Meter System is limited by size or by the number of types of services. Northern Arizona University currently operates as a Master Meter System. We purchase natural gas from Unisource Energy Services through four master meters and distribute natural gas through our internally owned and operated distribution system to buildings within our property line. Currently the piping systems total 42,467 feet in length, at pressures ranging from 10 to 54 psi, serving 112 risers with 5 pressure reducing stations and are not interconnected. The buildings are owned and operated by NAU, owned by NAU with portions rented to external entities, or have land leased to external organizations where they own and operate the buildings to support the primary mission of the university. The external organizations include retail, food service, laboratories, offices, and student housing and are charged for natural gas consumption through meters or rent. Upon review of interpretations Pl-03-0101 and Pl-73-030 it seems that a college or university is classified as a master meter system if there is underground piping and there are instances where the college or university is not the ultimate consumer. Additionally, there did not appear to be a limit to the size of systems, number of systems, or varying types of concessionaires or tenants. Based on the interpretations and regulations it seems that the Master Meter System definition does apply to NAU, and that our system is subject to the distribution regulations from 192-199 with the exceptions identified for a Master M eter System. Do you agree? Sincerely, Jon Heitzinger Associate Director of Utility Services Northern Arizona University#

Page 5W KAIBAB LN W M E TZ WALK 7 S P L A Z A WAY ST. GLOBE S. W.DUPONT AVE. W.CHATEAU DR. E. MCCRACKEN ST. S.BLACKBIRD ROOST W.ROUTE 66 WALK METZ W. North Plant S.MILTON RD. Regulator Station W. RIORDAN RD. 92 W . RI O RDAN RD. S. PL A Z A WAY ST. RANCH RIORDAN S. 4 27A 8 11 North East Master 55 Meter Zone 34 PSI MOUN T AIN VIEW DR S. MILTON RD. 14 S. RIORDAN RANCH ST. CHAMBERS DR. W.UNIVERSITY AVE. 15 S. MILTON RD. S. SAN FRANCISCO ST. GAS 18 59 59 19 E. S. MILTON RD. FOREST ST. W. MEADOWS S. MILTON RD. MCC O DR. TO NN E L L I-17SB 29 I-40 EBTOI-17 NB INTERS T ATE 17 I-17 TO SB I-40WB 36 W. SAUNDERS DR. 24 DR. W. MCCONNELL DR. TO ELL NB N I-17 ON MCC South Plant Master Meter 96 E. PINE KNOLL DR W. S.FLORENCE TOMBSTONE AVE. W.CLAY AVE. LN. S AI P L A M S. S.PARK ST. S.MIKES PIKE ROUTE 66 W. W. CLAY AVE. W. S.KENDRICK ST. BUTLER AVE. 1 S.MILTON RD. 2 2 S. KNOLES DR. GAS 3A 58A 58 W DUPONT AVE 58 S.HUMPHREYS ST. 57 3 5 1 MCMULLEN 4 CIR. 6 GAS 88 12 1 1 GAS 10 8 TORMEY 9 17 13A 13 GAS DR. (ONE-WAY) 19 20 15 5 16 16A Y ) 27 GAS A W 36 E - ABANDONED 21 18 Y ) NL O N O GAS R . ( _ 21B D ES 18A S 14 26 OSBORNE GAS 23A 24 23 IT-WAY (BU S N 22 A T TR MCCREARY DR. (ONE-WAY) GAS E TRE 86 GAS S 28 S. KNOLES DR. W. RIO R D 37 A N R D. 37A GAS APPLIANCES GAS 96A 12 54 90 54 54B 56 GAS VER A 31 BE 30 32 30C GAS S.HUMPHREYS ST. W.BENTON AVE. ST. (ONE-WAY) 3 BEAVER S. W.BUTLER AVE. ST. 91 BEAVER S. E. DUPONT AVE. 7A W. 93 ELLERY 6 AVE. E. FRANKLIN AVE. GAS . T S O GAS C I A F R N C S N S. S A 10 25 9 GAS GAS 33A 33 30B 30A 30D Y) GAS ONL GAS S GAS E 35 US B 40 39 38 TRANSIT-WAY ( GAS 60 96B TREET GAS S. KNOLES DR. GAS S R E 13 29 GAS AV E B 42 44 North Master 43 Meter Zone GAS 22 PSI 46 45 17 GAS UNIVERSITY DR. 50 50B 50 50 GAS 48 16 GAS S. KNOLES DR. 50 GAS GAS 47 50 50B 50B 50B 47A 50 50A GAS 50B 49 50B GAS RUNKE DR. 52 GAS GAS 20 S. KNOLES DR. 51 53 53 GAS 21 E. MCCONNELL DR. (ONE-WAY) 95 75 DR. (ONE-WAY) 75 65 30 E. MCC O N N E L L 81 69 74 82 82B E. PINE KN OL L DR. 75 61 75 26 64 63 66 67 GAS 72 South Plant Master 95 Meter Zone 95 18 PSI GAS 95 27 95 62 GAS E. PINE KNOLL DR 67 E. PINE KNOLL DR 68 31 GAS E. PHOENIX AVE. W. COTTAGE AVE. ST. . T U X S O R LE S. E. COTTAGE AGASSIZ S. AVE. ST. (ONE-WAY) E.BENTON AVE. FRANCISCO AGASSIZ ST. S.SAN S. E.BRANNEN AVE. E. BUTLER AVE. North Plant Master ST. Meter Zone FRANCISCO 47 PSI S.AGASSIZ ST. S.SAN E.DUPONT AVE. North Plant Master Meter E. ASHURST AVE. ST. ST. AGASSIZ VERDE S. S. E. FRANKLIN AVE. ST. O'LEARY S. S. O'LEARY ST. 55 96C ST. FOUNTAINE S. E. FRANKLIN AVE. S.FOUNTAINE ST. S. O'LEARY ST. 89 W. HOSKINS AVE. Greenhouse Regulator Station 7" WC I-17 NB TO I-40 WB 37 S. H U F F E RLN. 38 85 43 I-40WB TO I-17SB I-40 WB TO I-17 NB GAS 71 71 71 44 I40 WB TO I17 71 71 GAS 71 59 59 59 59 59 59 W.UNIVERSITY DR. 22 . T S. S A N FRA CIS C O N S 73 23 S. LONE TREE RD. RD. TREE S.LONE S. BR A N CIR. N E N W O O D LAN D DR. S PI N EG R O V E RD S PASE O DEL FL A G E. PINE KNOLL DR. 25 70 98A 98B S. LONE TREE RD. 32 79 GAS 76 78 84 97 39 45 28 E.PINE KNOLL DR. GAS 98F 98C 98D 33 80 80 77 83 GAS 77A 80B GAS GAS 80 GAS 77A 77A 80A South Master Meter Zone 34 PSI S. LONE TREE RD. 40 46 North East Master Meter McConnell Regulator Station South Master Meter 34 41 47 G A S L I N E Z O N E M A P & G I S G R I D 2 0 1 5 Gas Line Legend GAS, North Master Meter GAS APPLIANCES, North Master Meter GAS, NE Master Meter GAS APPLIANCES, NE Master Meter GAS, South Master Meter GAS APPLIANCES, South Plant Master Meter GAS, South Plant Master Meter GAS ABANDONED, North Master Meter _ NAU GIS Grid 60 20ac _ _ _ _ 1 inch = 843 feet 35 42 48#