{"operation":"document","citation":"PI-83-0111","title":"Pipeline Safety Interpretation PI-83-0111","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-12-19","effective_on":null,"summary":"PI-83-0111 concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-0111.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-0111.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-0111","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/g83-12-19_Schellenberg_192.3_Transmission%20Line-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-83-0111\nDecember 19, 1983\nMr. A. J. Schellenberg, P.E.\nGas Engineer, Lead Analyst\nPublic Service Commission\nCapitol Hill Building\n320 W. 25th Street,\nCheyenne, Wyoming 82002\nDear Mr. Schellenberg:\nThis responds to your November 16, 1983, letter regarding piping that supplies gas to\nindividually metered dwelling units from a tap on a transmission line. Your letter indicates that a\nutility company owns both the transmission line and customer meters. It also meters and\nregulates the gas at a point next to the transmission line. The piping between this point and the\ncustomer meters is not owned by the company, but by one of the customers who is the landlord\nof the other customers. You have asked whether the utility company or the owner is responsible\nfor compliance of this piping with the Federal safety standards in 49 CFR Part 192.\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 subject to Part 192 ends when gas\nhas been sold and delivered to a consumer. Under the facts given, the gas has been sold and\ndelivered to consumers at the outlets of the customer meters after passing through the piping in\nquestions. Thus, the piping in question is used in the transportation of gas that is subject to Part\n192.\nThe Natural Gas Pipeline Safety Act of 1968 (49 USC 1671 et seq.), under which the Part 192\nstandards were issued, provides in Section 10(a)(1) that:\n\"Each person who engages in the transportation of gas or who owns or operates pipeline\nfacilities shall-\n(1) at all times after any applicable safety standard established under this Act takes effect\ncomply with the requirements of such standard ....\"\nInasmuch as the utility company injects gas into the piping in question and uses the piping to sell\nand deliver gas to the customers, it is engaged in the transportation of gas with respect to that\npiping and, therefore, must meet the applicable Part 192 standards.\nAs the owner of the piping in question, the landlord is also responsible for compliance. In cases\nlike this where a utility company and a separate owner are each responsible for compliance, the\npolicy at the Federal level has been to enforce compliance by the utility before looking to the\nowner for compliance.\n192.3 TRANSMIL 1\n\n<<<PAGE 2>>>\n\nIf you need more direct help in this matter, I am sure that Jack Overly, Chief, Western Region,\nwill be glad to assist you.\nSincerely,\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n192.3 TRANSMIL 2","truncated":false,"body_characters":2611}