{"operation":"document","citation":"PI-74-0106","title":"Pennsylvania Public Utility Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-04-02","effective_on":null,"summary":"PI-74-0106 response to Pennsylvania Public Utility Commission concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0106.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0106.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0106","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-04-02_Rich_192.1-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0106\nApril 2, 1974\nMr. Jerry Rich\nCommonwealth of Pennsylvania\nPennsylvania Public Utility Commission\nBureau of Investigations, Service and\nEnforcement\nP.O. Box 3265\nHarrisburg, PA 17120\nDear Mr. Rich:\nThis responds to your letter of March 18, 1974, describing certain underground gas pipelines in an apartment\ncomplex. A utility-owned line stems from a street main and runs to a building where gas is metered and\ntransferred to customer-owned piping servicing apartments in that building. From the meter, another utility-\nowned line transports gas to a separate building where the gas is transferred to customer-owned piping serving\napartments in that building. You ask whether the customer-owned piping is subject to the Federal gas pipeline\nsafety standards and whether the owner of the piping is an operator within the meaning of those standards.\nThe Federal standards apply to pipelines used in the transportation of gas. We interpret the transportation of gas\nto end upon sale coupled with delivery to a consumer so that the gas is no longer in commerce. The question of\nhow far downstream the Federal standards apply depends on who buys and receives gas for consumption.\nIn the case of an apartment complex, if the landlord buys gas and, in turn, resells it to tenants for their\nconsumption, the underground or exterior lines used to transport the gas to tenants are a distribution system\nsubject to the Federal standards. The landlord, therefore, is engaged in the transportation of gas and an\n\"operator\" under the Federal standards.\nOn the other hand, if the landlord does not sell gas to tenants but uses it to provide centrally located heat or air\nconditioning for all tenants in a building, the landlord is the consumer and not an operator. The Federal safety\nstandards would only apply to pipelines located upstream from where the landlord receives the gas from a\nutility, i.e., from a customer meter or connection to the landlord's piping, whichever is further downstream.\nBased on these guidelines and information concerning the use of the gas, which is not included in your letter,\nyou should be able to determine whether or not the owner of the apartment complex in question is an operator.\nIf we may be of further assistance, please let us know.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n1","truncated":false,"body_characters":2350}