{"operation":"document","citation":"PI-72-001","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-01-13","effective_on":null,"summary":"PI-72-001 response to Memo: Internal concerning 191.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72001.pdf","body":"<<<PAGE 1>>>\n\nMEMORANDUM\nJanuary 13, 1972\nSUBJ: Reporting of leaks on customer-owned service lines\nFROM: Office of Regulation, TGC-20\nTO: Chief, Technical Division, TSA-32\nYou have asked for an opinion as to whether or not an\noperator of a gas distribution system is required under\nPart 191 to report leaks which occur on customer-owned\nservice lines to which he supplies gas. It is our\nopinion that an operator must report such leaks.\nThe Natural Gas Pipeline Safety Act applies to the\ntransportation of gas in or affecting interstate\ncommerce and to pipeline facilities used in that\ntransportation of gas. This jurisdiction includes such\nfacilities as customer meters and customer-owned\nservice lines that are used to transport gas.\nThe provisions of Part 191, issued under ?12 of that\nAct, require an operator to report leaks occurring on\nhis distribution system. Since an operator's system,\nas defined in Part 191, includes all pipeline\nfacilities which he uses to transport and distribute\ngas, customer-owned service lines are part of that\nsystem, and, as a consequence, leaks occurring on those\nservice lines must be reported by the operator.\nWilliam D. Broderick\ndal\\191\\1\\72-01-13","truncated":false,"body_characters":1188}