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Interpretation Response #PI-10-0011

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 08-04-2010
Individual Name: Judge Baughman
Country: US

View the Interpretation Document

Response text:

August 4, 2010

The Honorable William H. Baughman, Jr.
801 West Superior Avenue
Cleveland,OH 44113-1846

Dear Judge Baughman:

Thank you for your letter of June 11,2010, regarding Federal regulations pertaining to gas distribution pipeline leakage surveys and whether they are required inside of residences. As overseers of the Nation's 2.1 million miles of pipelines, the Pipeline and Hazardous Materials Safety Administration (PHMSA) is committed to ensuring safety and protecting the environment. Leakage surveys, as required under 49 CFR § 192.723, help ensure the safety of people who live and work in proximity to pipelines.

As you note in your letter, § 192.723 requires operators of a distribution pipeline system to conduct periodic leakage surveys. Pipelines not located in business districts must be surveyed at least once every five years. For cathodically unprotected distribution lines on which electrical surveys for corrosion are impractical, a leakage survey must be conducted at least once every three years.

Also, please reference 49 CFR § 192.3, which defines a service line as a distribution pipeline that transports gas from a common source of supply, such as a main, to one or more individual customers. A service line ends at the outlet of a customer's meter or at the connection to the customer's piping, whichever is farther downstream. If there is no customer meter, the service line ends at the connection to the customer's piping.

Under these provisions, an operator must conduct a leakage survey with leak detector equipment up to the end of the service lines. If the customer's meter or connection to the customer's piping is located inside a personal residence, the leakage survey must include that portion of the service line inside the residence.

Ohio is one of many states certified under 49 U.S.C. § 60105(a) to regulate intrastate natural gas pipelines, such as those discussed in this letter. Ohio regulates such pipelines through the Public Utilities Commission of Ohio (PUCO).

I hope this letter answers your questions and addresses your concerns. If we can be of further assistance, please do not hesitate to contact Elizabeth Komiskey (, phone: 202-288-1818), Harold Winnie (, phone: 816-329-3800) at our Central Region Community Assistance and Technical Services team in Kansas City, or me at 202-366-4595.


Alan K. Mayberry
Deputy Associate Administrator
For Field Operations

cc: Mr. Neil Eisner, Assistant General Counsel for Regulation and Enforcement, DOT Mr. Alan R. Schriber, Chairman, Public Utilities Commission of Ohio

Regulation Sections

Section Subject
§ 192.723 Distribution systems: Leakage surveys