Colorado Springs Utilities — Pipeline Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 OCT 3 0 2013 Mr. Mason Parsaye General Manager Colorado Springs Utilities 1521 Hancock Expressway Colorado Springs, CO 8094 7-1814 Dear Mr. Parsaye: In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated June 26, 2013, you requested an interpretation of the applicability of the Federal pipeline safety regulations at 49 CFR Part 192. Specifically, you requested clarification regarding the exemption to install an excess flow valve (EFV) on a service line per§ 192.383(b)(1). You stated that you have several pressure districts that are designed to operate as low as 5 psig and could operate at this pressure if load is high enough. You ask if all of the service lines in these pressure districts are exempted from EFV installation because your service lines are designed to operate below 1 0 psig? Also, you asked for clarification of the definition of "replaced service line." You asked whether a repair and/or replacement of a portion of a service line piping that is downstream ofthe tapping tee and the piping that is not physically attached to the tapping tee would require installation of an EFV. PHMSA's response to your first question is that performance standards have been established for EFV s that are installed on a service line that operates at or above 10 psig continuously during the year. However, service line pressure could be at its lowest level during the coldest weather, especially in colder climates. Therefore, pressure drop below 10 psig in the service line due to restriction of gas flow caused by an EFV could possibly cause a reduction in safety or loss of service. If your service lines are operating below 1 0 psig throughout the year, you are not required to install EFV s on those lines. Section 1 92.3 83(b )(1) states: § 192.383 Excess flow valve installation. (b) Installation required. An excess flow valve (EFV) installation must comply with the performance standards in § 192.381. The operator must install an EFV on any new or The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application ofthe regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 22 replaced service line serving a single-family residence after February 12, 2010, unless one or more of the following conditions is present: (1) The service line does not operate at a pressure of 10 psig or greater throughout the year; Regarding your second question, the definition for "replaced service line" in§ 192.383(a) states: § 192.383 Excess flow valve installation. (a) Definitions. As used in this section: Replaced service line means a gas service line where the fitting that connects the service line to the main is replaced or the piping connected to this fitting is replaced. PHMSA does not mandate additional excavation to install an EFV when another portion ofthe service line is excavated. However, PHMSA considers it is appropriate to require installation when the area near the connection to the main has been exposed and an opportunity to install an EFV exists. Ifwe can be of further assistance, please contact Tewabe Asebe of my staff at (202) 366-5523. Director, Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 3Colorado Springs Utilities It's how wt>'re all conrected June 26, 2013 IJ UL 0 2 2013 Jeff Weise, Associate Administrator for Pipeline Safety, PHP-1 Office of Pipeline Safety Pipeline and Hazardous Materiat Safety Administration U.S. Department of Transportation 1200 New Jersey Ave., SE Washington, DC 20590 ,,,. I I' · .. )· · RE: Clarification of §192.383, Excess flow valve installation Dear·Mr. Weise: '· Colorado Springs Utilities (CSU) would like to seek clarification regarding the first exemption to installing an Excess Flow Valve (EFV) on a service line per§ 192.383 (b)(1). Code reads as follows: (b) Installation required. An EFV installation must comply with the performance standards in §192.381 . The operator must install an EFV on any new or replaced service line serving a single-family residence after February 12, 2010, unless one or more of the following conditions is present: ( 1) The service line does not operate at a pressure of 1 0 psig or greater throughout the year; CSU has several pressure districts that are designed to operate as low as 5 psig and could operate at this pressure if losd is high enough. Are all of the service lines in these pressure districts exempted becsustJ they sre designed to operate below 10 psig? Also, CSU would like clarification of the definition of "Replaced servjce line". 1 !521 Hancock Expressway P. 0 . Box 1103, Mall Code 1814 Colorado Springe, CO 80947-1814 Phone: (719) ue.3503 . Fax: (719) 668-sn2 .. ! :)I I#

Page 4Jeff Weise, Associate Administrator for Pipeline Safety, PHP-1 June 26, 2013 Page2 Code reads as follows: Replaced service line means a gas service line where the fitting that connects the service line to the main is replaced or the piping connected to this fitting is replaced. Does this mean H we make s repsir sndlor rep/see s porlion of s tlflrvlceliM piping thst is downstream of the tJipplng tee AND the piping Is not phplcally attached to the tapping tee, we sre not required to lnst./1 sn EFV? Please provide clarification regarding these service lines. Best regards, c_k( ;{)~~~~ Mason Parsaye, General Ma ger Energy Construction, Operations & Maintenance Dept. c: Jessica Nesvold Stephan Pott, P.E.#