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Interpretation Response #PI-11-0009 ([State of Maine Public Utilities Commission] [Mr. Gary A. Kenny])

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

Interpretation Response Details

Response Publish Date:

Company Name: State of Maine Public Utilities Commission

Individual Name: Mr. Gary A. Kenny

Location State: ME Country: US

View the Interpretation Document

Response text:


Mr. Gary A. Kenny, PE
Gas Safety Manager
State of Maine
Public Utilities Commission
18 State House Station
Augusta, ME 04333-0018

Dear Mr. Kenny:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated June 10, 2011, you asked for an interpretation on the applicability of 49 CFR 192.1(b)(5) to a configuration of three hotel and/or motel rooms that are served by a liquefied petroleum gas (LPG) tank and its pipeline system. You provided a diagram of the pipeline system and described the diagram as follows:

  • Three hotel/motel guest rooms served by stubs off a common pipe;
  • Each guest room exits directly to the outside and they are not connected to any other structures;
  • Each stub provides LPG to a combination heating/cooling appliance in each of the guest rooms;
  • There are no meters; and
  • The tank(s), all piping, and the building are on private property.

Section 192.1(b)(5)(i) states that Part 192 does not apply to any pipeline system that transports only petroleum gas or petroleum gas/air mixtures to fewer than 10 customers, if no portion of the system is located in a public place.

In the diagram given, each room would constitute a customer. Because the LPG system serves three customers which is fewer than 10, it would be exempted from the Part 192 requirements if no portion of the system was located in a public place. However, churches, schools and commercial buildings are considered to be public places under the regulations. Hotels/motels are commercial buildings and, therefore, are public places. The diagram does not meet the exemption and the system would be a regulated system.

I hope that this information is helpful to you. If I can be of further assistance, please contact me at (202) 366-4046.


John A. Gale
Director, Office of Standards and Rulemaking

The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.

Regulation Sections

Section Subject
192.1 What is the scope of this part?