# Northern Arizona University — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-17-0012
- **title:** Northern Arizona University — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2017-12-11
- **effective on:** Not available
- **summary:** PI-17-0012 response to Northern Arizona University concerning 191.3.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0012.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0012.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0012
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/56626/northern-arizona-university-pi-17-0012-11-07-2017-part-1913.pdf
**body:**

<<<PAGE 1>>>

U.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 2>>>

2
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 3>>>

3
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 4>>>

NORTHERN
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 5>>>

W
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
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