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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-77-030 ([Public Service Commission of the District of Columbia] [Mary E. Brazelton])

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

Interpretation Response Details

Response Publish Date:

Company Name: Public Service Commission of the District of Columbia

Individual Name: Mary E. Brazelton

Location State: DC Country: US

View the Interpretation Document

Response text:

December 16, 1977

Ms. Mary E. Brazelton
Executive Secretary
Public Service Commission
of the District of Columbia
1625 I Street, N.W.
Washington, D.C. 20006

Dear Ms. Brazelton:

Thank you for your letter of November 18, 1977, expressing the Commission's concern over the safety of master meter systems in the District and indicating that with proper legal authority the Commission could take action to correct the problems.

We have for years advocated that State agencies (including the District) assume full regulatory jurisdiction over all intrastate pipeline facilities that are subject to the Natural Gas Pipeline Safety Act of 1968 (49 USC 1671 et seq.) Most areas where jurisdiction is lacking, such as master meter systems, are better suited for State than Federal enforcement activities.

However, until full jurisdiction can be achieved, the Act provides an alternative legal basis for State action. Under Sec. 5(b) of the Act (49 USC 1674(b)), a State agency may be authorized by agreement to carry out an inspection program on behalf of the Department for intrastate pipeline facilities not covered by an annual certification under Sec. 5(a). Although a Sec. 5(b) agreement would not empower a State agency to impose sanctions against violators, all other aspects of a compliance program could be carried out. If the Commission were to enter into such an agreement, we believe it would solve the immediate problem of not having legal authority to correct safety problems in master meter systems in the District. We would be happy to meet with you at your convenience to discuss this matter further.

As for the 1978 Seminar, master meter operators may be invited from the District. You should advise the Maryland and Delaware agencies of your plans as they may wish to do the same thing and there is a limit of 75 students from all three States.


Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

Section Subject
192.457 External corrosion control: Buried or submerged pipelines installed before August 1, 1971