{"operation":"document","citation":"PI-74-0153","title":"Utah Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-12-17","effective_on":null,"summary":"PI-74-0153 response to Utah Public Service Commission concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0153.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0153.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0153","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-12-17_Carlson_192.3_Master%20Meter-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0153\nDecember 17, 1974\nMr. Wayne L. Carlson, Inspector\nUtah Public Service Commission\n330 East 4th South\nSalt Lake City, UT 84111\nDear Mr. Carlson:\nThis refers to your letter of November 4, 1974, concerning the applicability of Part 192 to master meter systems in\ntrailer parks and apartment complexes.\nThe master meter systems subject to Part 192 are distribution systems used in the transportation of gas under the\nNatural Gas Pipeline Safety Act of 1968. We have interpreted this transportation to involve both the sale and delivery of\ngas through pipelines to where the gas is finally consumed. Where there is both a sale of gas, based either on a meter\nreading or a flat rate, and a delivery of gas by pipeline to an ultimate consumer, the person distributing the gas is\noperating a gas distribution system subject to Part 192. For instance, the owner of an apartment complex who furnishes\ngas to each tenant through pipelines and charges a flat rate for the gas as part of the monthly rent is an operator under\nPart 192. The pipelines subject to Federal jurisdiction are those transporting gas to the downstream side of each meter\nor to the customer's piping, whichever is farther downstream.\nWe trust this satisfactorily responds to your inquiry.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nPublic Service Commission\nState of Utah\n330 East 4th South\nSalt Lake City, Utah 84111\nNovember 4, 1974\nMr., Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDept. of Transportation\n800 Independence Ave., S. W.\nWashington D. C. 20590\nDear Mr. Caldwell:\nIn bringing mobile home parks under regulation of Section 192 Mr. Neil Wagstaff, owner of the Trailer City\ntrailer court in Provo, Utah, and also representing the Martin Trailer Court, which is relatively similar to his own, has\ncontested the fact that he should be responsible for compliance with Section 192. He feels that he is the ultimate\nconsumer of all the gas which is burned in his trailer park. He owns thirteen trailers and one duplex which are all master-\nmetered. He controls the turn-off and turn-on of the heat in the spring and fall and also controls the setting of the water\ntemperatures on the water heaters in each of these units. He does have gas stoves, which of course, are under the\ncontrol of the tenants. I have tried to explain to him that he was the intermediate consumer and not the ultimate\nconsumer, but he feels he should receive a ruling from your office. Would you please give us an answer on this question\nas soon as possible?\nWe have also been proceeding on multiple apartment units which are master-metered to require these people\nto become operators under 192 regulations and furnish the necessary inspection and maintenance plans and perform\nthe required functions. This is not specifically outlined in the discussion of the Amendment 192-15 redefining service\nlines, but in our discussion at Oklahoma City, it was our understanding that this was the intent of the law to bring all\nlines which were not regulated by local conditions under the jurisdiction of 192. Would you please comment on a\nseparate page on your reply on this matter?\nWe enjoyed the visit of your representative, Jim Abbee here in our office last Tuesday and feel that we gained a\nbetter understanding of where you want this program to go.\nYours truly,\nWayne L. Carlson, Inspector","truncated":false,"body_characters":3420}