{"operation":"document","citation":"PI-25-0001","title":"Louisiana DNR — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-04-23","effective_on":null,"summary":"PI-25-0001 response to Louisiana DNR concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-25-0001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-25-0001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-25-0001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-04/Louisiana-DNR-PI-25-0001-Combined-Response-Original-Letter-and-Graphics.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nApril 23, 2026\nMr. Steven Giambrone\nOffice of Conservation\nDepartment of Energy and Natural Resources\n617 North Third Street\nBaton Rouge, LA 70802\nDear Mr. Giambrone:\nBy letter dated January 31, 2025, the Louisiana Department of Natural Resources (LDNR)\nsubmitted a request for a written regulatory interpretation from the Pipeline Safety Hazardous\nMaterials Administration (PHMSA), Office of Pipeline Safety (OPS). Specifically, LDNR asked\nOPS whether the Federal gas pipeline safety regulations in 49 CFR Part 192 apply to a natural\ngas pipeline in St. John the Baptist Parish, Louisiana. OPS concludes that regulations in Part 192\napply to the pipeline for the reasons discussed below.\nBackground\nThe pipeline described in LDNR’s request is a lateral that connects to the Gulf South\ntransmission pipeline system in Louisiana, which is owned by DuPont de Nemours, Inc.\n(DuPont), and a petrochemical facility in St. John the Baptist Parish, LA. The pipeline was\npreviously operated by Gulf South as a part of its interstate natural gas pipeline system, but\noperatorship of the line was transferred to the owner, DuPont, in 2024. The line currently serves\nDuPont with natural gas, most of which is consumed by DuPont, but some is “redelivered” to a\npetrochemical facility owned by another entity who has a lease within the facility.\nThe letter states the location of the pipeline is primarily on DuPont property as shown in Figure 1\nbelow. The line crosses one road, DuPont Construction Road, which is a public road providing\naccess to the DuPont facility. It also crosses railroad tracks at two locations. The pipeline\nspecifications are as follows: 8.625\" OD x 0.322\" WT, Grade B, ERW. The maximum allowable\noperating pressure (MAOP) of the pipeline is 735 psig with an operating pressure of 285 psig.\nWhen Gulf South was operating the pipeline, they determined the line was in a Class 3 location\ndue to the proximity of a residential area and a school in relation to the pipeline. Operation at\nMAOP generates a hoop stress that is 28 percent of the Specified Minimum Yield Strength\n(SMYS). It is DuPont’s intention to lower the MAOP of the pipeline such that it falls below the\n20 percent SMYS threshold described in the definition of a transmission line at § 192.3.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\nPage 2 of 6\nThe letter also states there are two above-ground pressure regulator stations associated with this\nline. The first is at the connection with the Gulf South transmission pipeline. At this location,\nnatural gas enters a regulator station (on DuPont property), where pressure is lowered from\n1,016 psig to 285 psig. At the second station or “meter station,” the pressure is reduced further to\n200 psig and the gas is metered. The meter station is where Gulf South previously ended their\noperatorship of the pipeline, and DuPont has always operated the line downstream of the meter\nstation location.\nThe letter also indicates that inside of the facility, DuPont piping delivers gas to various areas for\nits own use and consumption. In addition to DuPont’s own use, DuPont delivers gas to Denka\nPerformance Elastomer (Denka) petrochemical facility within the boundaries of the DuPont\nfacility to be utilized by Denka for their operations. There is at least one meter within the DuPont\nfacility to measure the gas delivered to Denka, who is invoiced for its gas usage. The DuPont\nfacility is a Process Safety Management (PSM) facility and the pipelines within the facility are\ntreated as such. Additionally, DuPont states that the pipeline in question, from the tap with Gulf\nSouth transmission pipeline to the meter station, is also covered by Dupont’s PSM plan.\nRelevant Regulations\nOPS has determined that the following regulations are relevant in responding to LDNR’s request\nfor interpretation:\n§ 192.3 Definitions\nDistribution center means the initial point where gas enters piping used primarily to\ndeliver gas to customers who purchase it for consumption, as opposed to customers who\npurchase it for resale, for example:\n(1) At a metering location;\n(2) A pressure reduction location; or\n(3) Where there is a reduction in the volume of gas, such as a lateral off a\ntransmission line.\nDistribution line means a pipeline other than a gathering or transmission line.\nMaster Meter System means a pipeline system for distributing gas within, but not limited\nto, a definable area (such as a mobile home park, housing project, or apartment complex)\nwhere the operator purchases metered gas from an outside source for resale through a gas\ndistribution pipeline system. The gas distribution pipeline system supplies the ultimate\nconsumer who either purchases the gas directly through a meter or by other means, such\nas by rents.\nPipeline means all parts of those physical facilities through which gas moves in\ntransportation, including pipe, valves, and other appurtenance attached to pipe,\ncompressor units, metering stations, regulator stations, delivery stations, holders, and\nfabricated assemblies.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nPage 3 of 6\nService line means a distribution line that transports gas from a common source of supply\nto an individual customer, to two adjacent or adjoining residential or small commercial\ncustomers, or to multiple residential or small commercial customers served through a\nmeter header or manifold. A service line ends at the outlet of the customer meter or at the\nconnection to a customer's piping, whichever is further downstream, or at the connection\nto customer piping if there is no meter.\nTransportation of gas means the gathering, transmission, or distribution of gas by\npipeline or the storage of gas, in or affecting interstate or foreign commerce.\nTransmission line means a pipeline or connected series of pipelines, other than a\ngathering line, that:\n(1) Transports gas from a gathering pipeline or storage facility to a distribution\ncenter, storage facility, or large volume customer that is not down-stream from a\ndistribution center;\n(2) Has an MAOP of 20 percent or more of SMYS;\n(3) Transports gas within a storage field; or\n(4) Is voluntarily designated by the operator as a transmission pipeline.\nFigure 1.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nPage 4 of 6\nAnalysis\nPHMSA’s interpretation of 49 CFR Part 192 regarding the questions presented by LDNR are\nbelow:\nQuestion 1: Does the jurisdiction of a gas pipeline depend on whether or not it is located on the\nend user’s property? Since DuPont is a consumer of the gas and the gas enters its own pipeline\non its own property, does jurisdiction end at that point?\nPHMSA Response: In this case, DuPont is the consumer of part of the gas being transported on\ntheir property grounds but also sells gas to the Denka plant which is on DuPont property.\nInterpretation PI-07-0105 is instructive. In that interpretation, PHMSA considered the\njurisdictional endpoint of a lateral pipeline running from a transmission pipeline to an electrical\npower plant. Specifically, the requester asked if jurisdiction ends at the property line, fence line,\nfirst valve on the property, the power equipment, or another location. PHMSA responded:\n“Assuming the lateral pipeline in question is a transmission line as defined in § 192.3, pipeline\nsafety authority extends to the point where transportation ends, even if this point is on plant\nproperty. In many cases, the endpoint is where the lateral pipeline enters the plant grounds,\nusually at a security fence line. If, however, a measurement meter (or other component necessary\nto control the pressure or safety of the pipeline) is on the plant grounds, the endpoint would be\nthe meter (or other component, if the component is downstream of the meter).” In DuPont’s case,\nthe pipeline delivers gas to meters M1 and M2 (see Figure 1), which are downstream of the\nproperty line. Therefore, jurisdiction does not end at the property line.\nIt is important to understand that even though the pipelines in question in the reference\ninterpretation request refer to a transmission line, the same would apply to a distribution line as\nwell.\nQuestion 2: Does the jurisdiction of a gas pipeline depend on whether or not it is located behind\nthe fencing of an end user’s property?\nPHMSA Response: Similar to the response to Question 1, in this case there is a continuation of\nthe transportation of gas that extends beyond meter M1 to meter M2 at the Denka plant on the\nsame property grounds.\nAccording to the definition of a service line found in § 192.3, a service line ends at the outlet of\nthe customer meter or at the connection to a customer’s piping, whichever is further downstream,\nor at the connection to customer piping if there is no meter. Jurisdiction of a gas pipeline is a\nfunction of the location of the meter, not a property line or fence. This position is reiterated in\nInterpretation PI-12-0005 which clarified the end point of transportation for a natural gas\npipeline feeding two large volume customers was at the meter or pressure control device within\nthe pipeline owner’s property, not at the property boundary.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 5>>>\n\nPage 5 of 6\nQuestion 3: Does the fact that DuPont delivers gas (re-sale) to Denka change the jurisdictional\ndetermination?\nPHMSA Response: Yes. The fact that DuPont delivers gas to Denka (another end user) affects\nthe jurisdiction of the pipeline transporting gas from DuPont’s meter (M1) to the meter at\nDenka’s facility (M2). See Figure 1.\nThe pipeline that transports gas from the reduction in pressure (point RA in the diagram) to the\nmeter (M1) of the DuPont facility meets the definition of a distribution line and is jurisdictional\nto Part 192. This is because (RA) would be considered a “Distribution Center” in accordance\nwith § 192.3. Dupont’s pipeline delivering gas to Denka from meter (M1) to meter (M2) marked\nin blue in Figure 1, would also be considered a distribution line and is jurisdictional to Part 192.\nThe pipelines marked in yellow in Figure 1 are non-regulated pipelines by the Office of Pipeline\nSafety because they are customer owned piping used for the consumption of natural gas. Per\n§ 192.3 service line definition, a service line ends at the connection to customer piping if there is\nno meter.\nQuestion 4: Does the piping downstream of the meter station located outside the facility qualify\nas a master meter since some of the gas purchased by DuPont is re-delivered for sale to Denka?\nPHMSA Response: No. Meter (M1) is not a master meter.\nThe pipeline system downstream of meter (M1) is owned and operated by DuPont which sells\nsome of the gas to Denka at meter (M2). The pipeline that connects (M1) to (M2) owned by\nDuPont is a pipeline facility engaged in transportation and is subject to the jurisdiction of Part\n192. A “Master Meter System” is defined in § 192.3 as a pipeline system for distributing gas\nwithin, but not limited to, a definable area (such as a mobile home park, housing project, or\napartment complex) where the operator purchases metered gas from an outside source for resale\nthrough a gas distribution pipeline system. The gas distribution pipeline system supplies the\nultimate consumer who either purchases the gas directly through a meter or by other means, such\nas by rents.\nThe description of the pipeline facilities from M1 to M2 do not meet the conditions of a “Master\nMeter System” but rather is a pipeline delivering gas to a single petrochemical facility (Denka).\nQuestion 5: Can pipelines required to be covered by PSM plans also fall under DOT regulation?\nPHMSA Response: Our regulatory interpretation is limited to the applicability of the Federal\npipeline safety regulations. You will need to discuss the applicability of PSM plans with\nOccupational Safety and Health Administration (OSHA).\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 6>>>\n\nPage 6 of 6\nIf we can be of further assistance, please contact Joe Berry at (720) 601-3577.\nSincerely,\nCAMERON H Digitally signed by CAMERON\nH SATTERTHWAITE\nSATTERTHWAITE Date: 2026.04.23 15:48:50\n-\nCameron H. Satterthwaite\nActing Director, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 7>>>\n\nUS DOT OFFICE OF PIPELINE SAFETY\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHMSA)\nUS DEPARTMENT OF TRANSPORTATION\n1200 NEW JERSEY AVENUE, SE\nWASHINGTON, DC 20590-0001\nSubject: Interpretation Request, 192.1 (What is the scope of this part?)\nDear Mr. Mayberry,\nThe Louisiana Department of Energy and Natural Resources annually certifies a pipeline safety\nprogram with the US DOT. The Department, through the Office of Conservation, enforces the\nminimum pipeline safety standards for intrastate gas pipeline operators as defined in 49 CFR Part\n192. We request an interpretation of the code concerning a certain pipeline transporting natural\ngas in Louisiana, specifically, whether or not this line is subject to the requirements of 49 CFR\nPart 192.\nBackground:\nThe pipeline in question is a lateral connected to the Gulf South Pipeline system in Louisiana and\nis owned by DuPont de Nemours, Inc. (DuPont), a petrochemical facility in St. John the Baptist\nParish, LA. The pipeline was previously operated by Gulf South as a part of its interstate natural\ngas pipeline system, but operatorship of the line was transferred to the owner, DuPont, in 2024.\nThe line currently serves DuPont with natural gas, most of which is consumed by DuPont, but\nsome is redelivered to another entity who has a lease within the facility.\nThe location of the pipe is entirely on DuPont property as shown on the map (sourced from\nNPMS) with a few exceptions. The line crosses one road, DuPont Construction Road, which is a\npublic road providing access the DuPont facility. It also crosses railroad tracks at two locations.\nThe pipeline specifications are as follows: 8.625\" OD × 0.322\" WT, Grade B, ERW. The MAOP of\nthe pipeline is 735 psi with an operating pressure of 285 psi. When Gulf South was operating the\npipeline, they determined the line was in a class 3 location due to the proximity of a residential\narea and a school in relation to the pipeline. An MAOP of 735 psi generates a hoop stress that is\n28% of the SMYS of the pipeline, but the line is operated at a pressure such that the hoop stress\ngenerated is less than 20%. It is DuPont's intention to lower the MAOP of the pipeline such that\nit falls below the 20% threshold.\nPost Office Box 94396, Baton Rouge, LA 70804-9396 • 617 North Third Street, Baton Rouge, LA 70802\nPHONE: (225)342-2710 • FAX: (225)342-3790 • www.dnr.louisiana.gov\nAn Equal Opportunity Employer\n\n<<<PAGE 8>>>\n\nInside of the facility, DuPont piping delivers gas to various areas for their own\nutilization/consumption. In addition to DuPont's own use, DuPont delivers gas to Denka\nPerformance Elastomer (Denka) within the boundaries of the DuPont facility to be utilized by\nDenka for their operations within the facility. There is at least one meter (within the facility) to\nmeasure the gas delivered to Denka and they are invoiced for their gas usage. The DuPont facility\nis a Process Safety Management (PSM) facility and the pipelines within the facility are treated as\nsuch. Additionally, DuPont states that the line in question (from the tap with Gulf South to the\nmeter station) is also covered by their PSM plan.\nThe owner (and now current operator) of the pipeline believes that since this line is located on\nDuPont property, it is not jurisdictional to the DOT regulations. Historically, the Louisiana pipeline\nsafety program has regulated pipelines such as this up until such point where the line is inside\nthe facility fencing with jurisdiction ending at a valve/meter/etc. With the addition of the\ndefinition of \"Distribution Center\" added to the regulations, it is our contention that the pipeline\nin question is a service line up until the point where the gas is metered. The definition of\nDistribution Center is as follows:\nDistribution Center means the initial point where gas enters the piping used primarily to deliver\ngas to customers who purchase it for consumption, as opposed to customers who purchase it for\nresale, for example:\n(1) At a metering location;\n(2) A pressure reduction location; or\n(3) Where there is a reduction in the volume of gas, such as a lateral off a transmission line.\nService line means a distribution line that transports gas from a common source of supply to an\nindividual customer, to two adjacent or adjoining residential or small commercial customers, or\nto multiple residential or small commercial customers served through a meter header or a\nmanifold. A service line ends at the outlet of the customer meter or at the connection to a\ncustomer's piping, whichever is further downstream, or at the connection to customer piping if\nthere is no meter.\n\n<<<PAGE 9>>>\n\nTherefore, my requests is that PHMSA respond to the following questions:\n1) Does the jurisdiction of a gas pipeline depend on whether or not it is located on the end user's\nproperty? i.e. Since DuPont is a consumer of the gas and the gas enters their own pipeline on their\nown property, does jurisdiction end at that point? Or\n2) Does the jurisdiction of a gas pipeline depend on whether or not it is located behind the fencing\nof and end user's property?\n3) Does the fact that DuPont delivers gas (re-sale) to Denka change the jurisdictional determination?\n4) Is the piping downstream of the meter station located outside the facility qualify as a master\nmeter since some of the gas purchased by DuPont is re delivered for sale to Denka?\n5) Can pipelines required to be covered by PSM plans also fall under DOT regulation?\nIf you have any questions, I can be reached at (225) 342-2989 or Steven.Giambrone@la.gov.\nThank you in advance.\nYours truly,\nHe Seans\n-\nSteven Giambrone\nOffice of Conservation\n\n<<<PAGE 10>>>\n\nST. JOHN THE BAPTIST PARISH, LOUISIANA\nUD 25072\nUAC 5271\nNEX 2%. 3\n24°\n2028+70\nREGULATOR STATION\nDUPONT TIE-OVER\n- 172 NORCO PPEINE\n1078+83\nLAPLACE CITY GATE #2\nu/G\n272182) 130330) 294238 272183\nREGULATOR STATION\n3135+73\n®\n3152+63\n2° TAP TO ATMOS\n3168+00\nTO NEW ORLEANS\nVH3 M3N\nA3B8LS N13\n60-5E5\n272194\n272184\nS3178\n272200\n272191\nNO. 26\nHEMLOCK STREET\n3153+02\n275149\nUBNU\nJOHN ORY\n272192\nABANDONED\n272198\n272201\nLOUISIANA VALVE MAPS - 5452-KENNER\n3129+27 -\nABANDONED\nOBNO\n275150\nOBNO\nOBNO\n259296)\n259703)\nOBNO\n275143)\nOBNO\n275144)\nOBNO\n275145\nOBNO\n275142)\nOBNO\n275146\nOBNO\n272189)\nGaNG\nOBNO\nOBNO\nSOBNO\n275147)\nAFE 212257 ON 10/16/07\nOBNO\nVLNO\nGULF SOUTH\nREN KRF ISSUED\nSHT.\n620\nBY CHKD APPR SHEET 10F2\n\n<<<PAGE 11>>>\n\nBELLE POIN\n5th Ward\nElementary School\nDenka Performance\nElastomer\n44\nRS Seafood\nOur Lady of\n44\nGrace Church","truncated":false,"body_characters":21900}