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  • Andrew Geibel

Master Meter Definition according to 49 CFR 191 & 192

Updated: Oct 20, 2023

Section 191.3 defines a master meter system as: [A] pipeline system for distributing gas within, but not limited to, a definable area, such as a mobile home park, housing project, or apartment complex, where the operator purchases metered gas from an outside source for resale through a gas distribution pipeline system. The gas distribution pipeline system supplies the ultimate consumer who either purchases the gas directly through a meter or by other means, such as by rents.

To determine whether the operator meets the definition of a master meter system under 49 CFR § 191.3 and, therefore, is subject to the requirements of 49 CFR Parts 191 and 192, we must determine if the pipeline facilities are delivering gas to the ultimate consumer who pays for the gas directly, via a bill, or pays for the gas indirectly through other means, such as rents. In previous interpretations, PHMSA has stated that an entity would not meet the definition of a master meter system if it were only "using the gas delivered through its pipeline to provide heat or hot water to its buildings." 2 In that instance, the entity would be the consumer of the gas. PHMSA went on to say that if the entity provides gas to consumers, such as concessionaires, tenants, or others, it is engaged in the distribution of gas, and the persons to whom it is providing gas would be considered customers even though they may not be individually metered.

Master meter operators have less requirements than larger operators such as public gas utilities, but master meter operators are still required to have the following:

  1. Operations and Maintenance Procedure Manual

  2. Emergency Response Plan

  3. Public Awareness notifications

  4. Operator Qualified employees or contractors to maintain &work on any of the jurisdictional gas piping

  5. Conduct leak surveys, patrol the pipeline, emergency valve inspections, cathodic protection inspections, respond to leak & odor complaints, respond to one call tickets

  6. Member of the state One Call system

The Oak Tree Group specializes in providing these services. Let us help your company so that it's in full compliance with all state and federal requirements.

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