# Pipeline Safety Interpretation PI-78-0105

- **operation:** document
- **citation:** PI-78-0105
- **title:** Pipeline Safety Interpretation PI-78-0105
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1978-08-14
- **effective on:** Not available
- **summary:** PI-78-0105 concerning 192.3.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/g78-08-14_meredith_192.3_Service%20Line-nlmx.pdf
**body:**

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PI-78-0105
Date: 8/14/78
Names: Robert D. Meredith, City Attorney, Leitchfield, Kentucky
Subject: Mr. Meredith’s letter of July 24, 1978 (Control OPSR-41) Effect of location of service regulators on
liability.
Mr. Meredith’s letter stats that the city (the operator) will install a customer meter up to 100 feet from the pipeline.
Some of the potential customer is located as far as 1000 feet from the pipeline. To minimize the cost of service it is
desirable to carry high pressure in the service line up to the houses before installing a service regulator. In an attempt to
clarify several questions I called Mr. Meredith. I pointed out the definition of service line in 192.3 and that regardless of
ownership the requirements of 192.197 establishes the requirements for control of pressure of gas delivered from high
pressure distribution systems. He indicated that the main and service lines would be run with plastic pipe meeting the
requirements of 192.59 where the distance to the house exceeds 100 feet the customer is going to own the service line
beyond the meter and they will intend to locate the pressure regulator at or near the house. This will minimize the pipe
size required and assure adequate pressure for proper operation of customer owned appliances. I pointed out that the
outlet of the operator’s service regulator would then be the connection to the customer owned piping and that
regardless of ownership the facilities upstream of that point would be subject to part 192 and the operational
responsibility of the gas operator.
Paul Cory, P.E.
Conclusion: Cancel Control OPSR-41. No further action required
Date: 8/15/78
Paul J. Cory, P.E
Senior Engineer

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Meredith and Dinwiddie
80 Public Square
P.O. Box 466
Leitchfield, Kentucky 42754
July 24, 1978
Office of Pipeline Safety
Materials Transportation Bureau
Department of Transportation
Washington, D.C. 20590
Re: City of Leitchfield
Gentlemen:
The city of Leitchfield has recently constructed a natural gas transmission pipeline with an expected pressure of
100 lbs.
Customers along the line will need regulators. Our meters will be no further than 100 feet from our line, but the
services will, in many cases, be over 1000 feet from the meter. Just where do we put our regulators for efficient and safe
operation? What will be our liability if the regulators are installed by us near or by the residence? Should we require
our customer to purchase and install the regulators?
These questions were referred to your Atlanta office, but it requested we take them up with your office.
Sincerely yours,
Robert D. Meredith
City Attorney
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