Interpretation Response #PI-76-0114

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

Interpretation Response Details

Response Publish Date: 09/16/1976

Company Name:

Individual Name:

Location State: MD Country: US

View the Interpretation Document

Response text:

192.3 SERVICLI                                                                                      
                                                    1
Sep 16 1976
Ms. Joyce Ann Jurney
Property Manager Housing Services, Inc. Landover Mall West, Suite 202
Landover, Maryland  20785

Dear Ms. Jurney:
This responds to your letter of August 2, 1976, asking whether the piping downstream from a master
meter constitutes a gas distribution system subject to 49 CFR Part 192 if none of the piping is
exposed or underground.

A system which involves interior piping only (i.e., underground or exterior pipelines are not used
to distribute gas) is not a master meter system subject to 49 CFR Part 192.  The legislative
history of the Natural Gas Pipeline Safety Act of 1968, under which 49 CFR Part 192 is issued,
indicates that in authorizing the safety regulation of the distribution of gas by pipelines,
Congress had in mind those distribution systems which are primarily located outside.  Thus,
interior piping is only subject to regulation when it is included in an operator's system which is
otherwise
located outside.

We trust this response is helpful to you.
Sincerely,
Cesar DeLeon Acting Director Office of Pipeline Safety Operations
192.3 SERVICLI                                                                                      
                                                    2
HOUSING SERVICES, INC.
August 02, 1976

Office of Pipeline Safety Operations U.S. Department of Transportation Washington, D.C.  20590

Gentlemen:
Pursuant to correspondence received regarding the "Natural Gas Pipeline Safety Act of
1968", there are many regulations governing operators and/or distributors of gas pipeline systems.

This office received a bulletin from the Department of Housing and Urban Development in July of
1976 requesting that all owners and management agents of HUD insured housing projects are not in
violation of the Act.

Based on this HUD Information Bulletin (page No.1, Item No. 2), I do not consider us as an operator
as none of our pipes are exposed or go under ground again after reaching the master meter.

After numerous telephone calls I was advised by the Federal Housing Administration to contact your
office for the forms for certification for each of our properties, which are all apartment
complexes.

Please advise if my conclusion is in any way incorrect.  Your response will be appreciated.
Respectfully,
Joyce Ann Jurney
Property Manager

Regulation Sections