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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-81-0100

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name:

Location State: IA Country: US

View the Interpretation Document

Response text:

February 24, 1981

James L. Stanton, Esq.
517 ½ North Main Street
Carroll, Iowa 51401

Dear Mr. Stanton:
This is in response to your recent letter as well as to your telephone conversation with Mr.
Langley of our staff.

Gas pipeline safety standards are in 49 CFR part 192. Section 192.11 governs petroleum gas systems.
When a petroleum gas system, such as you describe, has fewer than 10 customers and no portion of
the system is in public place, it is not subject to the requirements of part 192 nor the industry
standards (National Fire Protection Association standards No.
58 and No.59) referenced in section 192.11. Also, we have previously interpreted section 192.11 as
not applying to
single tank single customer systems located on the customer’s property, even though the system may
cross part of the customer’s property that is a public place.

Although it appears that Federal regulations do not apply, there may be Iowa State regulations, as
Mr. Langley pointed out in your telephone conversation that do apply.

A copy of part 192, which you requested, is enclosed.
Sincerely, SIGNED
Melvin A. Judah
Acting Associate Director
Pipeline Safety Regulation
Materials Transportation Bureau

OPSO Advisory Bulletin No. 76-6                                                  June 1976          
                                                                               page 4

to 49 CFR,


Question:                    Under the Natural Gas Pipeline Safety Act of 1968, at what point in a
propane air peak-shaving facility does jurisdiction begin?
OPSO Interpretation: "In a propane air peak-shaving facility, liquid propane is vaporized and mixed
with air to supplement natural gas supplies during peak shaving.
All 'pipeline facilities' are within the jurisdiction of the Act.  'Pipeline facilities' are
defined in the Act to include 'without limitation . . . any equipment, facility, or building used
in the transportation of gas or the treatment of gas during the course of transportation' (49 USC
1671 (4)). Peak-shaving facilities are an interrelated and often essential part of a gas
distribution system and fall within the intended coverage of the term
'pipeline facilities.' Consequently, a propane air peak-shaving facility is in its entirety subject
to the jurisdiction of the Act."
James L. Stanton
Attorney at Law
517 ½ North Main Street
Carroll, Iowa 51401

December 29, 1980
U. S. Department of Transportation Research & Special Programs Admin. Washington, D. C. 20590
Request for Information-Natural Gas Pipeline Act of 1968
Presently I am involved in trying to resolve a dispute over the installation of a gas pipeline from
an LP gas tank located on the same property in which my client installed the gas line from the LP
tank to a building located on the same property. While I doubt very much that any federal
regulation applies to this project since we are not dealing with "interstate commerce", I am
advised that there might be certain federal regulations which might be applicable. In particular, I
would like to have a copy of the regulations of the office of the Secretary of Transportation, (49
CFR, Part I) and the Delegation of Authority to Director, Office of Pipeline Safety, 133 F.R.

I would appreciate your sending me copies of the above regulations and any other documents or
regulations which, in your opinion, might be applicable to the above situation. As I stated above,
I do not see how the federal regulation5would cover a purely "in house" project in which the source
of gas (LP tank) and the facility using the gas are connected by a pipeline all of which is on the
owner's property. Your comments in this regard would also be appreciated.

Very truly yours,
James L. Stanton

Regulation Sections

Section Subject
192.11 Petroleum gas systems