# Memo: Internal — Pipeline Safety Interpretation

- **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:** Not available
- **summary:** PI-72-001 response to Memo: Internal concerning 191.1.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72001.pdf
**body:**

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MEMORANDUM
January 13, 1972
SUBJ: Reporting of leaks on customer-owned service lines
FROM: Office of Regulation, TGC-20
TO: Chief, Technical Division, TSA-32
You have asked for an opinion as to whether or not an
operator of a gas distribution system is required under
Part 191 to report leaks which occur on customer-owned
service lines to which he supplies gas. It is our
opinion that an operator must report such leaks.
The Natural Gas Pipeline Safety Act applies to the
transportation of gas in or affecting interstate
commerce and to pipeline facilities used in that
transportation of gas. This jurisdiction includes such
facilities as customer meters and customer-owned
service lines that are used to transport gas.
The provisions of Part 191, issued under ?12 of that
Act, require an operator to report leaks occurring on
his distribution system. Since an operator's system,
as defined in Part 191, includes all pipeline
facilities which he uses to transport and distribute
gas, customer-owned service lines are part of that
system, and, as a consequence, leaks occurring on those
service lines must be reported by the operator.
William D. Broderick
dal\191\1\72-01-13
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