# Pipeline Safety Interpretation PI-76-0100

- **operation:** document
- **citation:** PI-76-0100
- **title:** Pipeline Safety Interpretation PI-76-0100
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1976-01-19
- **effective on:** Not available
- **summary:** PI-76-0100 concerning 192.1.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0100.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0100
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-01-19_BULLA_192.1-nlmx.pdf
**body:**

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PI-76-0100
January 19, 1976
Mr. John Bulla
R. A. Ransom Company, Inc.
1000 Connecticut Avenue, N.W.
Washington, D.C. 20036
Dear Mr. Bulla:
Your letter of September 4, 1975, requests clarification of the responsibility for compliance with
corrosion control and leakage survey requirements with respect to a pipeline owned by a public
housing authority running between the housing authority's meter on an apartment building wall
and a road right-of-way. From the right-of-way, the pipeline continues to a gas main operated by
a public utility.
Under Section 8 of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1677) and 49 CFR Part
192, a person who engages in the transportation of gas (operator) is responsible for compliance
with Part 192 as to all pipelines used in that transportation. As indicated by the definition of the
term "service line" in Section 192.3, an operator engages in the transportation of gas to the point
where the sale and delivery of gas to a customer have occurred.
In the situation you describe, it appears that the public utility engages in the transportation of gas
to the outlet of the meter. Therefore, as the operator, the public utility is responsible for
compliance with the corrosion control and leakage survey requirements for the pipeline between
the main and the meter. Whether the housing authority or the public utility bears the cost of
compliance as to that portion of the pipeline not owned by the utility is a matter outside the
jurisdiction of this Office.
We trust this satisfactorily responds to your inquiry.
Sincerely,
Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations
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