{"operation":"document","citation":"PI-83-003","title":"Colorado Public Utilities Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-03-19","effective_on":null,"summary":"PI-83-003 response to Colorado Public Utilities Commission concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-003.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-003.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-003","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83003.pdf","body":"<<<PAGE 1>>>\n\nMarch 19, 1983\nMr. Milt Schneider\nGas Pipeline Safety Engineer\nColorado Public Utilities Commission\nDepartment of Regulatory Agencies\n500 State Services Building\n1525 Sherman Street\nDenver, Colorado 80203\nDear Mr. Schneider:\nEnclosed is an interpretation issued in response to your letter of March 15, 1983.\nPlease note that your use of the term \"service line\" does not conform to the Part 192 definition,\nand therefore, the word \"pipeline\" has been substituted in the question. The pipelines you are\nconcerned about are \"customer piping\" within the meaning of the \"service line\" definition in\n§192.3 and thus, not covered by Part 192.\nSincerely,\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nEnclosure\ndal\\192\\3\\83-03-19\n1\n\n<<<PAGE 2>>>\n\nNo. 83-4\nDate: April 19, 1983\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\n_\nPIPELINE SAFETY REGULATORY INTERPRETATION\n_\nNote: This pipeline safety regulatory interpretation applies\na particular rule to a particular set of facts\nand circumstances, and as such, is binding\nonly on the operator to whom the\ninterpretation is specifically addressed.\nSECTION: 192.3\nSUBJECT: Mobile home park pipelines.\nFACTS: In a mobile home park, natural gas is transported from mains owned by the utility\ncompany (in the utility easement) through company meters located at each individual lot line to\nburied pipelines owned by the park and then to the connector at each individual mobile home.\nQUESTION: Are these pipelines subject to the requirements of Part 192? If yes, who is\nresponsible for compliance activities?\nINTERPRETATION:\nPart 192 applies to pipelines used in the transportation of gas. In accordance with the definition\nof \"service line\" in §192.3, the pipeline transportation that is regulated by Part 192 does not go\nbeyond the point where gas has been sold and delivered to a consumer.\nIn the example, gas is sold to each mobile home consumer when it passes through the meter.\nWhere, though, do the consumers take delivery of the gas? Since the pipelines between the\nmeters and the mobile homes are owned by the park, we presume the park leases the lots on\nwhich the mobile homes are located to the mobile home consumers. Because these pipelines are\nintended to benefit the consumers, it can also be presumed that each lease carries with it a right of\nthe consumer to use the pipeline to\ndal\\192\\3\\83-03-19\n2\n\n<<<PAGE 3>>>\n\n2\nreceive gas. We, therefore, consider the mobile home consumers to be receiving gas at the outlet\nof the meters. Thus, gas is both sold and delivered to a consumer when it leaves the meter, and\nPart 192 does not apply to the downstream piping.\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\ndal\\192\\3\\83-03-19\n3\n\n<<<PAGE 4>>>\n\nMarch 15, 1983\nRichard L. Beam, Associate Director\nPipeline Safety Regulation\nMaterials Transportation Bureau, DOT\n400 7th Street Southwest\nWashington, D.C. 20590\nDear Mr. Beam:\nI respectfully request an interpretation of service line responsibilities.\nIn a mobile home park, natural gas is transported from mains owned by the utility company (in the\nutility easement) through company meters located at each individual lot line to buried service lines\nowned by the park and then to the connector at each individual mobile home.\nQuestion: Are these service lines subject to the requirements of Part 192? If yes, who is\nresponsible for compliance activities?\nYour assistance would be appreciated.\nVery truly yours,\nMilt Schneider, P.E.\nGas Pipeline Safety Engineer\ndal\\192\\3\\83-03-19\n4","truncated":false,"body_characters":3652}