{"operation":"document","citation":"PI-04-0105","title":"Mueller Company - Gas Products Division — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-04-20","effective_on":null,"summary":"PI-04-0105 response to Mueller Company - Gas Products Division concerning 192.145.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2004/g04-04-20_Deering_192.145-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-04-0105\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\nApril 20, 2004\nMr. Connor J. Deering\nMueller Company - Gas Products Division\nDecatur, IL 62525\nDear Mr. Deering:\nThis is in response to your e-mail of March 26, 2004, in which you request an interpretation of the provisions of\nthe Federal gas pipeline safety regulations at 49 CFR 192.145, Valves, as it relates to the use of brass valves in gas\npipeline systems.\nAlthough the use of brass body valves in gas pipeline systems is not explicitly excluded by the pipeline\nsafety regulations, the pipeline operator must be able to demonstrate how these valves comply with the regulations.\nThis includes a showing that the valves comply with American Petroleum Institute standard API 6D, Specification for\nPipeline Valves, or an equivalent standard. The regulations also require the operator to have written procedures for\ninstallation and maintenance of brass valves. In addition, where a gas distribution pipeline system is regulated by a state\nagency, the state is free to be more restrictive, as long as it is not inconsistent with the Federal regulations.\nBrass body valves are typically used as shutoff valves on gas service lines. It has been asserted by some suppliers\nthat such valves comply with the requirements of the American National Standards Institute's (ANSI) standard ANSI\nB16.33, Manually Operated Metallic Gas Valves for Use in Gas Piping Systems up to 125 psig (Sizes 1/2 Through 2).\nAnd, you are no doubt aware that the American Society of Mechanical Engineer's standard ASME B31.8, Gas\nTransmission and Distribution Piping Systems, allows valves manufactured according to ANSI B16.33 or API 6D for use in\ngas service lines if the valves meet certain other requirements.\nIn any case, an operator installing a brass body valve would need to ensure that it complies with the rest of\nthe regulations in § 192.145. For example, § 192.145(b)(2)(ii) requires testing of valves to 1.5 times the maximum\nservice rating. This is a more stringent seat test than API 6D (1.5 vs. 1.1). It is not unusual for a regulation to call for\ncompliance with a standard, but to also prescribe additional or more stringent requirements. An operator would need\nto specify a 1.5 times seat test in their orders to valve manufacturers to comply with the requirements of § 192.145.\nIn response to your specific questions:\n1. Does the U.S. Department of Transportation require that natural gas meter valves meet API 6D?\nOPS Response: Yes. All valves used in gas distribution and transmission systems must meet the minimum\nrequirements, or equivalent, of standard API 6D.\n2. Although API 6D has strict material composition requirements, section 382, Composition Limits,\nstates that \"all alternate metallic materials shall have compositions with a minimum of 50% by weight\nof any combination iron, nickel, or cobalt and a maximum of 0.45% by weight of carbon.\" Does brass\nmeet these requirements?\nOPS Response: No.\n\n<<<PAGE 2>>>\n\n3. Are you aware of an \"equivalent\" standard that would allow brass as an acceptable material for natural gas\nmeter valves?\nOPS Response: Some pipeline operators have cited ANSI B16.33 as an equivalent standard for brass body\nservice line valves. The applicability of any particular standard and its acceptability as an equivalent\nstandard for brass body service line valves would need to be supported by the pipeline operator and\nreviewed by OPS and state pipeline safety inspectors on a case-by-case basis.\n4. If brass is not acceptable under API 6D, and no \"equivalent\" standard exists, is brass an acceptable\nmaterial for natural gas meter valves?\nOPS Response: Brass is not banned from use on natural gas meter valves, but it is not directly addressed in either § 192.145\nor in API 6D. As noted above, it is the responsibility of a pipeline operator to justify its use based on compliance with an\nequivalent standard.\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 3>>>\n\nHuriaux, Richard\nFrom: Connor Deering [cdeering@muellercompany.corn]\nSent: Friday, March 26, 2004 10:22 AM\nTo: Huriaux, Richard\nSubject: Request for Formal Interpretation\nRichard — it was a pleasure speaking with you the other day. After our conversation I have reviewed the information I\nhad and would like to request a formal interpretation of several aspects related to natural gas meter valves, material\nrequirements, and compliance with API 6D. The issues I am requesting a formal interpretation on are the following:\n1. Does the United States Department of Transportation require that natural gas meter valves meet API 6D?\n2. While I am aware that you do not exclusively prohibit materials, API 6D has strict material composition\nrequirements, section 382 \"Composition Limits\" states\n\"All alternate metallic materials shall have compositions with a minimum of 50% by weight of any combination of iron,\nnickel, or cobalt and a maximum of 0.45% by weight of carbon\", does brass meet these requirements?\n3. I understand that there is an \"equivalent\" clause in API 6D that would give an option for alternate materials, are\nyou aware of an \"equivalent\" standard that would allow brass as an acceptable material for natural gas\nmeter valves?\n4. If brass is not acceptable under API 6D, and no \"equivalent\" standard exists, is brass an acceptable material for\nnatural gas meter valves?\nI appreciate your time and consideration on this matter, if you have any questions please feel free to contact me at your\nconvenience.\nBest Regards,\nConnor J. Deering\nMueller Co. - Gas Products Division\nNational Sales and Marketing Manager (800) 798-3131 x7520\n\n<<<PAGE 4>>>\n\nSeptember 3, 1999\nMr. R.C. Cobb\nNational Sales & Marketing Manager\nGas Products Division\nMueller Company\n500 West Eldorado Street\nP.O. Box 671\nDecatur, Illinois 62525\nDear Mr. Cobb:\nAs your letter of September 1, 1999, notes the concept of \"equivalent\" as used in our regulations at. In\nSubpart D, § 192.143 states that each component must be able to withstand the pressure and other\nloadings it will encounter in gas service and that a valve must \". . . meet the minimum requirements, or\nequivalent, of API 6D.\" This means that compliance with API 6D is not necessary, but that the pipeline\noperator must be able to show how a valve meets an \"equivalent\" specification or standard.\nThe language you cite in API 6D, Section 3.8, Alternate Metallic Materials, does appear to exclude the use of\nbrass an acceptable material. However, the term equivalent\nEquivalent does not mean exactly the same, but it does mean that any equivalent standard would need to\naddress all the concerns expressed in API 6D. I believe you are right that the use of brass would be a stretch,\nalthough it is not specifically excluded by the \"or equivalent\" language.\n####\nOne point of clarification I would appreciate has to do with the material requirements as specified in API 6D. I\nunderstand the concept of “equivalent” as you pointed out in your response. However, API 6D seem to\naddress the issue of non-steel metals in section 3.8. “Alternate metallic Materials shall have coimpositions\nwith a minimum of 50% by weight of any combination of iron, nickel or cobalt and a maximum of 0.45% by\nweight of carbon.” This would appear to exclude the use of brass as an acceptable material.\n####\n******\nThis is in response to your letter of April 29, 1999, regarding whether forged brass-body shut-off valves are\nacceptable in a gas meter installation valve for natural gas service. You correctly note that the gas pipeline\nsafety regulations (49 CFR 192) make no mention of brass-body valves and that Subpart B, Materials, and\nSubpart D, Design of pipeline Components, do not provide clear direction on this issue.\nHowever, the regulations do provide general direction for acceptable valves. All valves must be able to\nmaintain the integrity of the pipeline under temperature and other environmental conditions, be chemically\ncompatible with the gas and other materials in the pipeline with which they are in contact, and must be\nqualified in accordance with the applicable requirements of Subpart B. Of course, the rest of subpart B\naddresses only steel pipe and plastic pipe, and does not refer to brass or other materials of which a valve\ncould be made, except to state that it must be marked with the specification to which it was manufactured.\nThe use of brass is therefore possible under Subpart B.\nIn Subpart D, §19.143 states that each component must be able to withstand the pressure and other loadings\nit will encounter in gas service and that a valve must “. . . meet the minimum requirements, or equivalent, of\n\n<<<PAGE 5>>>\n\nAPI 6D.\" This means that compliance with API 6D is not necessary, but that the pipeline operator must be able\nto show how a valve meets and \"equivalent\" specification or standard.\nThe bottom line is that the use of forged brass-body valves for gas meter shut-off valve service is not excluded\nby the regulations. For that matter, neither is any other material. But, any material used must be able to\nmeet the general serviceability requirements of Subpart B and Subpart D, which include compliance with API\n6D, or an equivalent technical standard. It is up to a pipeline operator to determine what it will accept as\n\"equivalent.\"\nYou should be aware that the Office of Pipeline Safety cannot 'approve' or 'certify' manufactured gas\npipeline components as being in compliance with the Federal pipeline safety regulations. The regulations\napply only to the regulated gas transmission and distribution pipeline companies. These companies have full\ndiscretion to decide that a particular component does, or does not; comply with the Federal pipeline safety\nregulations. That determination can only be made by the pipeline operator after consideration of the system\nin which the devices are to be installed, the corrosive conditions that may exist, and other design factors. Of\ncourse, this judgment on the part of the pipeline operators is reviewable by the Federal inspectors and our\nstate-level agents.\n********\nIf we can be of further assistance in this matter, please contact me at (202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\n\n<<<PAGE 6>>>\n\nInterpretation 192.145 3\nDecember 17, 1970\nMr. William H. Alexander Project Engineer\n320 Hughes Street\nHouston, Texas 77011\nDear Mr. Alexander:\nThis is in reply to your letter of February 17, 1971, concerning the interpretation of 49 CFR, Section 192.145(a).\nPublished specifications do not exist for all types and sized of valves that are manufactured; however, there are\ncertain basic safety design features that can be adapted to all these valves.\nThe word \"equivalent\" is used in the sense of providing equivalent safety. For example, the listed\nspecifications do not cover all sizes and types of valves, but a valve of a size or type not covered should at least\nmeet the applicable safety requirements in the listed specifications.\nThank you for your interest in the pipeline safety program.\nSincerely,\nSIGNED\nJoseph C. Caldwell\nDirector, Acting\nOffice of Pipeline Safety","truncated":false,"body_characters":11315}