{"operation":"document","citation":"PI-04-0104","title":"Virginia State Corporation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-04-05","effective_on":null,"summary":"PI-04-0104 response to Virginia State Corporation Commission concerning 192.197.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0104.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0104.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0104","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2004/g04-04-05_Hotinger_192.197-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-04-0104\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\nApril 5, 2004\nMr. Jim Hotinger\nSenior Utilities Engineer\nVirginia State Corporation Commission P.O. Box 2118\nRichmond, VA 23216\nDear Mr. Hotinger:\nThis is in response to your e-mail of February 10, 2004, in which you request an interpretation of the gas\npipeline safety regulations at 49 CFR 192.197(a). You ask whether an external line supplying gas to a pilot controlling the\noperation of a regulator is a \"static\" or \"control\" line within the meaning of the section.\nSection 192.197(a) states that no other pressure limiting device is required for a distribution system operating at\nless than 60 psig if the regulator conforms to six requirements. One of these requirements (at § 192.197(a)(6)) is that the\nregulator is self-contained with no external static or control lines. If there is an external static or control line, another\npressure limiting device is required.\nIn an interpretation issued June 29, 1992, the Office of Pipeline Safety (OPS) said that \"the 'static or control line'\n. . . is a line that runs from the regulator to the downstream side of the regulator used to communicate that pressure to\nthe regulator.\" Under this interpretation, an external line connected to the regulator from the upstream side is NOT a\nstatic or control line.\nHowever, we have reason to believe that this interpretation was in error. A static or control line is an external\nline from a regulator that is connected to the main or service line either upstream or downstream and is necessary for\nthe safe functioning of the regulator. A \"self-contained service regulator\" as used in § 192.197(a)(6) does not require any\nexternal line(s) to function correctly or has internal overpressure protection, such as a relief or monitor. Another\npressure limiting device is required if a regulator includes external static or control lines and does not have any internal\noverpressure protection, such as a relief or monitor.\nIf you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nHuriaux, Richard\nFrom:\nSent:\nTo:\nSubject:\nHotinger, Jim\nTuesday, February 10, 2004 11:46 AM\nHuriaux, Richard\nClarification of Interpretation 192.197, No. 13, June 29, 1992.\nI have printed the full text of the interpretation at the end of this email. I would like a review of this interpretation to\nexplain how a line supplying gas to the pilot controlling the operation of a regulator is NOT “static” or “control” line. The\nregulator cannot function properly without this pilot which cannot function without the line supplying gas. If this is not\na “static” or “control” line, what is it? If this interpretation is accurate, then (as 192.192 stated in part) “…no other\npressure limiting device is required.” This could mean that a single failure of this regulator may overpressure the\nremainder of the service line and the customer’s fuel line. This particular style of regulator may have an “internal\nmonitor” built into it for overpressure protection, but do all regulators with external lines connected to upstream\npressure have built in overpressure protection, i.e., and American 1800 CPB2 regulator/ Please let me know your\nthoughts. Thank you for looking into this matter for me. –Jim Hotinger\nInterpretation 192.197 13 June 29, 1992\nMr. Ronald J. Boes\nManager of Gas Systems Standards & Procedures Indiana Gas Company\n1630 North Meridian Street Indianapolis, IN 46202-1496\nDear Mr. Boes:\nThis responds to your letter of April 17, 1992, to Mr. Richard Sanders of the Transportation Safety Institute in which you\nask if the 3/8\" external line on the Sprague CL34-2 IMR regulator is a \"static or control line\" as set forth in Section\n192.197.\nThe \"static or control line\" in Section 192.197(a)(6) is a line that runs from the regulator to the downstream side of the\nregulator used to communicate that pressure to the regulator. The 3/8\" external tubing on the Sprague CL34-2 IMR is\nnot a static or control line, but a supply line supplying high pressure gas from the inlet side of the regulator to the pilot\nto establish the set point; i.e., the outlet pressure of the regulator.\nI trust that this has adequately responded to your question.\nSincerely,\nCesar De Leon\nDirector\nRegulatory Programs\nOffice of Pipeline Safety","truncated":false,"body_characters":4493}