Pipeline Safety Interpretation PI-76-0109

Page 1PI-76-0109 August 30, 1976 Mr. R. H. Greene Resident Engineer and Superintendent of Physical Plant Stephen F. Austin State University Nacogdoches, Texas 75961 Dear Mr. Greene: This refers to your letter of July 20, 1976, asking whether the natural gas system operated by Stephen F. Austin State University is subject to the Natural Gas Pipeline Safety Act of 1968 and the regulations issued thereunder, contained in 49 CFR Part 192. Your letter indicates that the University purchases gas at 10 master meter locations and uses it for hot water and heating purposes, but also distributes the gas to students for cooking purposes. We consider any person to be subject to the Act and the regulations who is purchasing gas and selling and delivering it by pipeline to others for their consumption. From the information you have provided, it appears that the University is selling gas to students through the rental being charged for their use of the student housing. Therefore, the University's system would be subject to the Act and the regulations. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations 192.3 SERVICLI 1#

Page 2STEPHEN F. AUSTIN STATE UNIVERSITY July 20, 1976 Mr. Joseph C. Caldwell, Director Office of Pipeline Safety Department of Transportation Washington, DC 20590 Dear Mr. Caldwell: I have read the Natural Gas Pipeline Safety Act of 1968 (Public Law 90-481) and need your assistance to determine whether the University is considered to be a gas system operator. Stephen F. Austin State University is a tax supported state institution. Natural gas is supplied to our campus at ten (10) master meter locations. The University then distributes the gas to approximately 70 campus buildings through the University owned gas distribution system. The gas is used to fire boilers to provide hot water for heating and domestic purposes and by students living in married student housing for cooking. It is our intention to provide safe facilities and to comply with all applicable federal, state and local laws. However, due to the shortage of funds available to us, we have to consider all needs and exercise prudent judgement as to how the funds are to be used. If we are covered by the Act then we will take immediate steps to comply. If not, we propose to continue our present study with a consulting firm specializing in corrosion control to determine whether we need to use special protective devices on our gas system. We will appreciate your response to this letter as soon as possible. Yours truly, R.H. Greene Resident Engineer and Superintendent of Physical Plant 192.3 SERVICLI 2#