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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-73-005 ([New Mexico State Corporation Commission] [John A. Elliott])

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

Interpretation Response Details

Response Publish Date:

Company Name: New Mexico State Corporation Commission

Individual Name: John A. Elliott

Location State: NM Country: US

View the Interpretation Document

Response text:

Mr. John A. Elliott
Director, Pipeline Division
New Mexico State Corporation Commission
P. O. Drawer 1269
Sante Fe, New Mexico 87501

Dear Mr. Elliott:

This is in reply to your letter of January 3, 1973, in which you ask the following. "One of our
L.P. gas operators has one hundred (100) customers. They are served from thirty-eight (38)
separate tanks with no more than seven (7) on one tank. Are they required under Section 192.11
to meet the standards of Part 192?

The requirements of section 192.11 are applicable, in pertinent part, to "a system that serves 10 or
more customers." With respect to this particular section, the OPS considers a system to consist
of a separate tank and the facilities serving the customers from that tank. The term "tank" also
includes a tank group consisting of interconnected tanks. Thus, if a tank serves less than 10
customers, the associated system does not come within the regulation. The fact that an operator
has two or more separate tanks serving a total of 10 or more customers does not bring the
combined operation within the regulation, but any separate tank and facilities serving 10 or more
customers constitute a system subject to the requirement.

If we may assist further in this matter, please call on us.


Joseph C. Caldwell
Office of Pipeline Safety

Regulation Sections

Section Subject
192.11 Petroleum gas systems