{"operation":"document","citation":"PI-96-002","title":"Virginia State Corporation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-02-13","effective_on":null,"summary":"PI-96-002 response to Virginia State Corporation Commission concerning 191.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96002.pdf","body":"<<<PAGE 1>>>\n\nMr. Massoud Tahamtani\nUtilities Manager\nDivision of Energy Regulation\nVirginia State Corporation Commission\nP.O. Box 1197\nRichmond, VA 23209\nDear Mr. Tahamtani:\nI am responding to your letter about three distribution piping systems. on whether the systems are subject to Part 192.\nYou requested our opinion\nThe definition of \"service line,\" in § 192.3, represents the limit of Part 192 jurisdiction over gas\ndistribution piping. Under this definition, Part 192 jurisdiction ends at the outlet of a meter that\nmeasures the transfer of gas to a consumer, or at the connection to piping not owned by an\noperator through which a consumer receives gas, whichever point is farther downstream.\nThe first system you described begins at a transmission line and distributes gas to a farm house\nand outbuildings, including the residence of a farm worker who receives gas as part of his pay.\nUnder these circumstances, it is reasonable to assume that the worker's residence and associated\npersonal consumption of gas is an intrinsic part of the farming business. Thus, all gas transferred\nto the farm is consumed by the farm, and the farm is not an operator. If the transmission line\ndelivers metered gas to farm piping, the jurisdiction of Part 192 ends at the outlet of the meter. there is no meter, jurisdiction ends where the operator's piping connects to farm piping.\nIf\nThe second system transports gas to a public school, which has multiple buildings and buried gas\npiping. The school charges community organizations a fee to occasionally use the school\ncafeteria and gas cooking appliances under the supervision of a school employee. In this case,\nboth the school and the organizations consume gas through the same equipment. But the school\nis by far the largest and most frequent consumer of gas through that equipment. As such, for\npurposes of determining Part 192 jurisdiction, it is reasonable to consider the school solely as a\nconsumer, and not as an operator. Assuming the operator delivers metered gas to the school,\nPart 192 jurisdiction ends at the outlet of the meter.\nThe third system fuels street and entrance lighting in a planned community. The community\nassociation maintains the system and pays a flat fee to the local gas company for all the gas\nconsumed. Because nobody other than the association is consuming any of the gas, the\nassociation is the consumer for purposes of determining Part 192 jurisdiction. Thus, in the\nabsence of a meter, Part 192 jurisdiction ends where the gas company's piping connects to the\ncommunity association's piping.\nI hope you find these opinions useful. 366-4565.\nIf you need any further assistance, please call me at (202)\n05/06/99 191.3 (Master Meter)\n192.3 (Service Line)\n96-02-13.doc\n\n<<<PAGE 2>>>\n\nSincerely,\nRichard D. Huriaux, P.E.\nDirector for Technology and Regulations\nOffice of Pipeline Safety\ncc:\nDPS-11, 10, 20; DCC-1; DPS-2, 1, 24; TSI\nDPS-11:LMFurrow:366-2392:2/13/96\nFILE: 192 gen\n05/06/99 191.3 (Master Meter)\n192.3 (Service Line)\n96-02-13.doc","truncated":false,"body_characters":3022}