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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-83-0102

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: CO Country: US

View the Interpretation Document

Response text:

February 9, 1983

Mr. Milt Schneider
Gas Pipeline Safety Engineer
Department of Regulatory Agencies
Colorado Public Utilities Commission
500 State Services Building
1525 Sherman Street
Denver, Colorado 80203

Dear Mr. Schneider:

Your letter to me of January 28, 1993, asks three questions relating to the responsibility of a
master meter operator versus a supplier for certain facilities used to supply gas to a master meter
operator. Your questions and the OPSR response are as follows:

Case 1:                The gas supplier (municipal) requires the property developer to provide gas
service piping to the property line. The activity requires a permit from the regional building
department and is subject to inspector and approval by a regional building department inspection.  
The installation must meet the requirements of the gas supplier (a different of branch government).
Upon completion and acceptance, the gas supplier installs a master meter at (1) a convenient
location; or (2) at the building(s).

Question:           At which point on the service line does the supplier responsibility end
192.13(c) and the master meter operator responsibility begin? Does the property line have any

Response:          Compliance with 49 CFR Part 192 is the responsibility of the pipeline operator.
Since the supplier would have operational control of the gas through the meter and piping upstream
of the master meter, the supplier would be responsible for that piping. The property line has no
significance in this determination.

Case:                   The supplier in Case I performs leak surveys on service lines to the meter
but has no records as to the location of service lines. Leaks are red tagged and the customer is
required to have same repaired by a licensed plumber.

Question:            Does this leak survey satisfy the minimum requirements of part 192.723 for the
supplier? Does the survey satisfy the requirement for the master meter operator if the meters are
at the building?

Response:          For the supplier the answer is yes, provided leakage surveys meet all applicable
provisions of §192.723.
From the information you provided, it is not possible to determine whether the leakage survey would
meet any obligation the master meter operator might have.

Final Question: The “Guidance Manual For Operators of Small Gas Systems” shows a drawing of a
master meter piping system showing master meter operator’s responsibility. Does this drawing have
an official interpretation status?

Response:          The drawing referred to is not an official interpretation by Materials
Transportation Bureau, but rather should be considered as advisory material or as a training aid.
Original signed by
Richard L. Beam
Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau

Regulation Sections

Section Subject
192.3 Definitions