# Corrosion Associates, Inc — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-73-0109
- **title:** Corrosion Associates, Inc — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1973-06-01
- **effective on:** Not available
- **summary:** PI-73-0109 response to Corrosion Associates, Inc concerning 192.3.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-06-01_Doll_192%203_Service%20Line-nlmx.pdf
**body:**

<<<PAGE 1>>>

PI-73-0109
06-01-73
Mr. William C. Doll
Corrosion Associates, Inc
Box 303
Westminster, Colorado 80030
Dear Mr. Doll:
In our letter of February 5, 1973, we advised that the answer to your inquiry concerning
responsibility for certain gas pipelines would depend on the revised definition of "service line"
when it became effective. You had asked " who is responsible for the cathodic protection on a
gas line after the line goes into the meter and back into the ground?"
The revised definition of "service line," published as Amendment 192-13 to Part 192, Title 49 of
this Code of Federal Regulations (38 R.R. 9083), became effective May 10, 1973. The new
definition reads as follows:
"Service line" means distribution line that transports gas from a common source of supply
to (1) a customer meter or the connection to a customer's piping, whichever is farther
downstream, or (2) the connection to a customer's piping if there is no customer meter,
A customer meter is the meter that measures the transfer of gas from an operator to a consumer.
Under the definitions of Part 192, an operator is a person who engages in the transportation of
gas. The transportation of gas is regulated to the downstream end of the distribution system.
Since a distribution system normally ends in a service line, the operator is the person responsible
that a service line meets all applicable regulations.
Your question does not describe any particular situation so we assume you are referring to a
usual case such as an individual customer meter serving a residential home.
Consistent with the new definition of "service line," if piping downstream of the meter is owned
by the customer, such piping is not included within the definition and, therefore, is not covered
by the regulations. In such case, the service line extending down to and including the meter is
the responsibility of the operator. On the other hand, if any of the piping downstream of the
meter is owned by the operator, such piping, down to the point where it connects to the
customer's piping, is a service line and the operator is responsible for compliance with the
applicable regulations including the cathodic protection requirements.
I trust this answers your question. If we may be of further assistance, please call on us.
192.3 SERVICLI 1

<<<PAGE 2>>>

Sincerely,
Joseph C. Caldwell
Director
Office of Pipeline Safety
192.3 SERVICLI 2

<<<PAGE 3>>>

Feb 5 1973
Mr. William C. Doll
Corrosion Associates, Inc.
Box 303
Westminster, Colorado 80030
Dear Mr. Doll:
This will acknowledge receipt of your letter of January 18, 1973, asking "Who is responsible for
the cathodic protection on a gas line after the line goes into the meter and back into the ground?"
Since your question is not directed to a particular situation, the answer in certain cases will
depend on what is included within the definition of "service line" as set forth in section 192.3 of
the Federal pipeline safety standards. The Office of Pipeline Safety expects to issue in the near
future a revised definition of "service line." We would, therefore, prefer to answer your inquiry
consistent with the revised definition when it becomes effective.
If you have a question with regard to a specific situation, we will be pleased to respond.
Sincerely,
Joseph C. Caldwell
Director
Office of Pipeline Safety
192.3 SERVICLI 3
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