{"operation":"document","citation":"PI-73-0101","title":"Division of Pipeline Safety State of Nebraska — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-01-04","effective_on":null,"summary":"PI-73-0101 response to Division of Pipeline Safety State of Nebraska concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-01-04_Minniear_192.3_Master%20Meter-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-73-0101\n01-04-73\nMr. Harley Minniear, Director\nDivision of Pipeline Safety\nState of Nebraska\nDepartment of Fire Prevention\nLincoln, Nebraska 68509\nDear Mr. Minniear:\nThis is in reply to your letter of December 5, 1972, asking who is responsible for carrying out the\npipeline safety regulations in the situation described.\nAs we understand the situation, a gas transmission company delivers gas through a master meter\nto the owner of a trailer court. The trailer court owns all piping downstream of the master meter\nand delivers gas to 145 metered customers of the court. The gas company reads and bills the\ncustomer meters and provides necessary repairs and services to the trailer court. The trailer court\nowner is billed for the difference between the sum of the 145 meters and the amount shown on\nthe master meter.\nOn December 18, 1970, this office sent to the Chairman of each State agency having jurisdiction\nover gas pipeline safety a letter discussing, among other systems, a mobile home park system\nsupplied from a single master meter. In that situation, there were no separate meters for\nindividual tenants who were charged a flat rate. Under those conditions, the mains and service\nlines downstream of the master meter are considered to be a distribution system subject to the\nNatural Gas Pipeline Safety Act, and the landlord of the mobile home park is considered an\noperator under the gas pipeline safety regulations.\nIn the situation you now present, the tenants are individually metered with the meters read and\nbilled by the serving gas company. Nevertheless, it is clear that the trailer court owner is\nresponsible for the cost of all gas transmitted through the master meter. As with the master meter\nsystem discussed in the December 8, 1970 letter, the landlord in effect is purchasing gas from the\ncompany and distributing it from a single master meter to the various tenants in the trailer park.\nThe fact that the gas is metered to each tenant rather than going unmetered and charges at a flat\nrate does not affect the designation of the landlord's piping as a distribution system or the\nlandlord as an operator. Under §192.3 of the regulations, a service line is defined as a\ndistribution line that transports gas to a customer meter set assembly from a common source of\nsupply. Where there are individual customer meters, the distribution system is regulated to the\noutlet side of each customer meter set assembly. The Department considers the work\n\"customers\" to mean the last person who purchases the gas before its consumption. the trailer\n192.3 MASTERME 1\n\n<<<PAGE 2>>>\n\npark system in your situation, therefore, more closely approximates a conventional distribution\nsystem than the system discussed in the December 18, 1970 letter.\nThe method by which the owner chooses to service its system does not alter the responsibility.\nInsofar as compliance with safety regulation is concerned, the landlord is free to contract with\nany person or company to perform necessary repairs or services on landlord-owned lines or to\nread the meters and collect the bills. Such arrangements, however, do not divest the owner of the\nresponsibility.\nIn summary, the pipelines downstream of the master meter providing gas to the tenants in a\ntrailer park constitute a distribution system subject to the Natural Gas Pipeline Safety Act.\nWhether or not the tenants of that park are individually metered and regardless of the person\nemployed by the trailer park to perform necessary services, the owner of the trailer park's gas\ndistribution system is the operator under our regulations. The operator has the responsibility for\ncomplying with the safety regulations including the ordorization and cathodic protection\nrequirements which you specifically mentioned.\nI trust this answers your inquiry. If there are additional questions, please contact us.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n192.3 MASTERME 2","truncated":false,"body_characters":3964}