Interpretation Response #PI-76-0109

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

Interpretation Response Details

Response Publish Date: 08/30/1976

Company Name:

Individual Name:

Location State: TX Country: US

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Response text:

192.3 SERVICLI                                                                                      
                                                    1
August 30, 1976
Mr. R. H. Greene Resident Engineer and Superintendent of Physical Plant Stephen F. Austin State
University Nacogdoches, Texas  75961

Dear Mr. Greene:
This refers to your letter of July 20, 1976, asking whether the natural gas system operated by
Stephen F. Austin State University is subject to the Natural Gas Pipeline Safety Act of 1968 and
the regulations issued thereunder, contained in 49 CFR Part 192.

Your letter indicates that the University purchases gas at 10 master meter locations and uses it
for hot water and heating purposes, but also distributes the gas to students for cooking purposes.

We consider any person to be subject to the Act and the regulations who is purchasing gas and
selling and delivering it by pipeline to others for their consumption.  From the information you
have provided, it appears that the University is selling gas to students through the rental being
charged for their use of the student housing.  Therefore, the University's system would be subject
to the Act and the regulations.
Sincerely,
Cesar DeLeon Acting Director Office of Pipeline Safety Operations
192.3 SERVICLI                                                                                      
                                                    2
STEPHEN F. AUSTIN STATE UNIVERSITY
July 20, 1976

Mr. Joseph C. Caldwell, Director Office of Pipeline Safety Department of Transportation Washington,
DC  20590

Dear Mr. Caldwell:

I have read the Natural Gas Pipeline Safety Act of 1968 (Public Law 90-481) and need your
assistance to determine whether the University is considered to be a gas system operator.

Stephen F. Austin State University is a tax supported state institution.  Natural gas is supplied
to our campus at ten (10)   master meter locations.  The University then distributes the gas to
approximately 70 campus buildings through the University owned gas distribution system.  The gas is
used to fire boilers to provide hot water for heating and domestic purposes and by students living
in married student housing for cooking.

It is our intention to provide safe facilities and to comply with all applicable federal, state and
local laws.  However, due to the shortage of funds available to us, we have to consider all needs
and exercise prudent judgement as to how the funds are to be used.  If we are covered by the Act
then we will take immediate steps to comply.  If not, we propose to continue our present study with
a consulting firm specializing in corrosion control to determine whether we need to use special
protective devices on our gas system.

We will appreciate your response to this letter as soon as possible.
Yours truly,
R.H. Greene
Resident Engineer and
Superintendent of Physical Plant

Regulation Sections