{"operation":"document","citation":"PI-72-049","title":"NACE Accreditation No. 21 — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-11-07","effective_on":null,"summary":"PI-72-049 response to NACE Accreditation No. 21 concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-049.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-049.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-049","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72049.pdf","body":"<<<PAGE 1>>>\n\nNovember 7, 1972\nMr. Charles Kirklen\nCorrosion Specialist\nNACE Accreditation No. 21\n931 Blue Lake Circle\nRichardson. Texas 75080\nDear Mr. Kirklen:\nThis is in response to your letter of October 17, 1972, regarding the applicability of Subpart I, 49\nCFR Part 192, to the natural gas system serving an apartment complex. As you describe the\nsystem, the owner of an apartment complex purchases gas from a public utility through one or\nmore central meters located on the apartment property and distributes the gas by an underground\npiping system. Each building in the complex is then served by a riser, with attached regulator,\nfrom the underground system.\nYou ask whether steel underground pipes and steel risers from underground plastic pipes of such\na system are subject to the corrosion control requirements of Part 192. If so, you further ask\nwhether the owner is required to file an annual report.\nYour description of the system does not disclose the disposition of the gas once it leaves the riser\nin each apartment building. If the gas is being distributed to individual apartment units for further\nconsumption by persons other than the apartment complex owner, then the mains and service lines\ndownstream of the master meter extending to the outlet side of each individual apartment\n(customer) meter (or if there is no meter, to a point where a customer meter would normally be)\nare considered a distribution system and the apartment owner an operator. In this situation, the\ndistribution system is required to conform to the requirements of Part 192 including corrosion\ncontrol. As part of the distribution system, the risers are subject to the corrosion control\nrequirements to the extent indicated in Subpart I.\nOn the other hand, if the gas is being distributed only to a central heating or air conditioning unit\ninside each apartment building so that individual apartment units do not receive gas but are\nfurnished heat or air conditioning, then the gas remains the property of the apartment complex\nowner. Such a system would normally not be a distribution system subject to the requirements of\nPart 192.\nWith reference to your other question, there are no annual reporting requirements in connection\nwith Subpart I of Part 192. However, §191.11 requires that each operator of a distribution\nsystem submit an annual report. Therefore, if the owner or landlord is the operator of a\nDAL\\192\\3\\72-11-07\n1\n\n<<<PAGE 2>>>\n\ndistribution system as explained above, he is required to submit an annual report in accordance\nwith §191.11\nI trust this answers your inquiry.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDAL\\192\\3\\72-11-07\n2","truncated":false,"body_characters":2679}