# Pipeline Safety Interpretation PI-76-0114

- **operation:** document
- **citation:** PI-76-0114
- **title:** Pipeline Safety Interpretation PI-76-0114
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1976-09-16
- **effective on:** Not available
- **summary:** PI-76-0114 concerning 192.1.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0114.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0114
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-09-16_Jurney_192.1-nlmx.pdf
**body:**

<<<PAGE 1>>>

PI-76-0114
Sep 16 1976
Ms. Joyce Ann Jurney
Property Manager
Housing Services, Inc.
Landover Mall West, Suite 202
Landover, Maryland 20785
Dear Ms. Jurney:
This responds to your letter of August 2, 1976, asking whether the piping downstream from a
master meter constitutes a gas distribution system subject to 49 CFR Part 192 if none of the
piping is exposed or underground.
A system which involves interior piping only (i.e., underground or exterior pipelines are not used
to distribute gas) is not a master meter system subject to 49 CFR Part 192. The legislative
history of the Natural Gas Pipeline Safety Act of 1968, under which 49 CFR Part 192 is issued,
indicates that in authorizing the safety regulation of the distribution of gas by pipelines, Congress
had in mind those distribution systems which are primarily located outside. Thus, interior piping
is only subject to regulation when it is included in an operator's system which is otherwise
located outside.
We trust this response is helpful to you.
Sincerely,
Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations
192.3 SERVICLI 1

<<<PAGE 2>>>

HOUSING SERVICES, INC.
August 02, 1976
Office of Pipeline Safety Operations
U.S. Department of Transportation
Washington, D.C. 20590
Gentlemen:
Pursuant to correspondence received regarding the "Natural Gas Pipeline Safety Act of
1968", there are many regulations governing operators and/or distributors of gas pipeline
systems.
This office received a bulletin from the Department of Housing and Urban Development
in July of 1976 requesting that all owners and management agents of HUD insured housing
projects are not in violation of the Act.
Based on this HUD Information Bulletin (page No.1, Item No. 2), I do not consider us as
an operator as none of our pipes are exposed or go under ground again after reaching the master
meter.
After numerous telephone calls I was advised by the Federal Housing Administration to
contact your office for the forms for certification for each of our properties, which are all
apartment complexes.
Please advise if my conclusion is in any way incorrect. Your response will be
appreciated.
Respectfully,
Joyce Ann Jurney
Property Manager
192.3 SERVICLI 2
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