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Is Your Campus/Complex A Natural Gas Master Meter System?

Posted by Ben Klopp on Tuesday, September 6, 2022

Good question! The answer might depend on who you ask.

If you distribute natural gas amongst multiple buildings or users within a defined area, you may qualify. Master Meter System Operators have recordkeeping and reporting requirements that can blindside owners and lead to fines and penalties. More on that later, let’s start by defining a Master Meter system.

What is a Master Meter System?

Master Meter systems are defined by the Federal Pipeline and Hazardous Materials Safety Administration (PHMSA) in 49 CFR § 191.3 as:

Master Meter System means 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.

Master Meter Systems in Pennsylvania

In Pennsylvania, like many other states, Master Meter Systems fall under the jurisdiction of PA’s utility regulator, the Public Utility Commission (PUC). Act 127, also known as the Pipeline Act, granted this authority to the PUC. The PUC makes an important distinction that to qualify as a master meter operator, gas service must be to property owned by a 3rd party (PA PUC Act127 FAQs). So, if all the property is owned by a single entity, ie – a college or healthcare campus, that would not qualify as a Master Meter System. But, if any of the buildings, units, etc. which are supplied are owned by another, ie – mobile home park, they would meet the definition of a Master Meter System.

If your system qualifies as a Master Meter System the PUC requires system registration and annual renewals. Click Here for More information from the PUC.

An important distinction in the PHMSA definition is that a Master Meter Operator does not even need to directly charge those connected to its distribution system for the natural gas, it can be incorporated into rent.

What are the Requirements of Master Meter System Operators?

Master Meter System Operators may be subject to the PHMSA’s Federal requirements to maintain a Distribution Integrity Management Program (DIMP). In addition, each state may have additional or more stringent requirements, which need to be reviewed in your system’s state. The Federal DIMP requirements can be found in detail in Distribution Integrity Management Guidance for Master Meter and Small Liquefied Petroleum Gas Pipeline Operators.

DIMP Summary:

Knowledge of System Infrastructure – basic information on the distribution system. Mapping, descriptions, installation information, responsible parties, etc.
Identification of Threats – what types of events or activities could cause damage to the system? Corrosion, excavations, natural disasters, etc. are examples.
Risk – evaluation of the threats identified in #2, to determine their likelihood of occurrence.
Risk Mitigation – identification and implementation of measures to reduce the risks associated in #3.
Performance Evaluation – how well is the system performing? Documentation of leaks, repairs, etc.
Evaluation and Improvement – reviewing and updating the items above at minimum every 5 years.
Records – DIMP plans and documents must be maintained for at least 10 years.
Reporting – There are no annual reporting requirements for Master Meter System Operators, however your PIMP plan and documents must be available to regulators upon request.

What’s Next?

Step #1 would be to determine if your system qualifies as a Master Meter System, so you can understand your requirements and complete any Federal and State compliance requirements. Whether or not your gas distribution system qualifies as a Master Meter System, having a DIMP in place, and/or knowing the whereabouts of your natural gas systems will improve the safety and effectiveness of your system operations.

If you have questions or need help, please contact me. Additionally, you can view the Master Meter Operator compliance services that we offer.