# Division of Pipeline Safety State of Nebraska — Pipeline Safety Interpretation

- **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:** Not available
- **summary:** PI-73-0101 response to Division of Pipeline Safety State of Nebraska concerning 192.3.
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- **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>>>

PI-73-0101
01-04-73
Mr. Harley Minniear, Director
Division of Pipeline Safety
State of Nebraska
Department of Fire Prevention
Lincoln, Nebraska 68509
Dear Mr. Minniear:
This is in reply to your letter of December 5, 1972, asking who is responsible for carrying out the
pipeline safety regulations in the situation described.
As we understand the situation, a gas transmission company delivers gas through a master meter
to the owner of a trailer court. The trailer court owns all piping downstream of the master meter
and delivers gas to 145 metered customers of the court. The gas company reads and bills the
customer meters and provides necessary repairs and services to the trailer court. The trailer court
owner is billed for the difference between the sum of the 145 meters and the amount shown on
the master meter.
On December 18, 1970, this office sent to the Chairman of each State agency having jurisdiction
over gas pipeline safety a letter discussing, among other systems, a mobile home park system
supplied from a single master meter. In that situation, there were no separate meters for
individual tenants who were charged a flat rate. Under those conditions, the mains and service
lines downstream of the master meter are considered to be a distribution system subject to the
Natural Gas Pipeline Safety Act, and the landlord of the mobile home park is considered an
operator under the gas pipeline safety regulations.
In the situation you now present, the tenants are individually metered with the meters read and
billed by the serving gas company. Nevertheless, it is clear that the trailer court owner is
responsible for the cost of all gas transmitted through the master meter. As with the master meter
system discussed in the December 8, 1970 letter, the landlord in effect is purchasing gas from the
company and distributing it from a single master meter to the various tenants in the trailer park.
The fact that the gas is metered to each tenant rather than going unmetered and charges at a flat
rate does not affect the designation of the landlord's piping as a distribution system or the
landlord as an operator. Under §192.3 of the regulations, a service line is defined as a
distribution line that transports gas to a customer meter set assembly from a common source of
supply. Where there are individual customer meters, the distribution system is regulated to the
outlet side of each customer meter set assembly. The Department considers the work
"customers" to mean the last person who purchases the gas before its consumption. the trailer
192.3 MASTERME 1

<<<PAGE 2>>>

park system in your situation, therefore, more closely approximates a conventional distribution
system than the system discussed in the December 18, 1970 letter.
The method by which the owner chooses to service its system does not alter the responsibility.
Insofar as compliance with safety regulation is concerned, the landlord is free to contract with
any person or company to perform necessary repairs or services on landlord-owned lines or to
read the meters and collect the bills. Such arrangements, however, do not divest the owner of the
responsibility.
In summary, the pipelines downstream of the master meter providing gas to the tenants in a
trailer park constitute a distribution system subject to the Natural Gas Pipeline Safety Act.
Whether or not the tenants of that park are individually metered and regardless of the person
employed by the trailer park to perform necessary services, the owner of the trailer park's gas
distribution system is the operator under our regulations. The operator has the responsibility for
complying with the safety regulations including the ordorization and cathodic protection
requirements which you specifically mentioned.
I trust this answers your inquiry. If there are additional questions, please contact us.
Sincerely,
/signed/
Joseph C. Caldwell
Director
Office of Pipeline Safety
192.3 MASTERME 2
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