{"operation":"document","citation":"PI-13-0011","title":"Palermo Plastics Pipe (P3) Consulting — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-06-09","effective_on":null,"summary":"PI-13-0011 response to Palermo Plastics Pipe (P3) Consulting concerning 192.281.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2013/Palermo_Plastics-PI-13-0011-06-09-2014-Part_192.281%28a%29.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nJUN - 9 2014\nDr. Gene Palermo\nPalermo Plastics Pipe (P3) Consulting\n654 Watershaw Drive\nFriendsville, TN 3 773 7\nDear Dr. Palermo:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nOctober 1, 2013, you requested an interpretation of a requirement of the Federal gas pipeline\nsafety regulations at 49 CFR Part 192. Specifically, you asked whether the§ 192.281(a)\nrestriction on the use of miter joints applies to factory-made large diameter mitered tees and\nelbows.\nYou stated that for pipe sizes 12 inches and less in diameter, gas operators generally use molded\nfittings; however, for pipe sizes greater than 12 inches, molded fittings are not as readily\navailable and gas operators need to use tees and elbows that are fabricated in a factory using\nseveral miter joints. You asked if a gas operator can install a fabricated fitting (tee or elbow)\ncontaining miter joints if the fitting was made in a factory under the regulations, or whether a\nspecial permit would be required.\nIn reviewing the relevant code sections,§ 192.281(a) states:\n(a) General. A plastic pipe joint that is joined by solvent cement, adhesive, or heat fusion\nmay not be disturbed until it has properly set. Plastic pipe may not be joined by a\nthreaded joint or miter joint.\nHowever, the scope of 49 CFR Part 192, Subpart F does not apply to joining during the\nmanufacture ofpipe or pipeline components. Section 192.271(b) states:\n(b) This subpart does not apply to joining during the manufacture of pipe or pipeline\ncomponents.\nIn order to address your question, PHMSA reviewed the reference standards applicable to plastic\npipe fittings. Appendix AI ofthe American Society for Testing and Materials (ASTM) D2513-\n99, which is incorporated by reference in Part 192, addresses plastic pipe diameters greater than\n12 inches and up to 24 inches. Section Al.4 of this appendix addresses fittings. It states that for\nbutt-type fittings, the fittings must meet the requirements of ASTM D 3261. Section 4.1.2 of\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nASTM D 3261 states that fittings fabricated by thermal welding are not included in this\nspecification.\nTherefore, the referenced standard is not applicable to fabricated fittings. If an operator plans to\nuse a fabricated fitting greater than 12 inches, the operator must first apply for a special permit\nunder 49 CFR 190.341.1\nIf we can be of further assistance, please contact Tewabe Asebe of my staff at 202-366-5523.\nSincerely,\nA~\nc/ Johri A. Gale\nDirector, Office of Standards\nand Rulemaking\n1 With regard to the September 1979 letter to Mr. Petro ofPlexco referenced in your request, it addresses the non-\napplicability of§ 192.281 to manufactured fittings but does not discuss the requirements to qualify a fabricated\nfitting for use.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\np\n·.~ f'\nPalermo Plastics Pipe (P3\n)\nConsulting\nDr. Gene Palermo\nwww.plasticspipe.com\nPalermo Plastics Pipe (P3\n) Consulting\n654 Watershaw Drive\nFriendsville, TN 37737\nEmail: gpalermo@plasticspipe.com\nPhone: 865-995-1156\nCell: 703-201-8987\nOctober 1, 2013\nMr. Jeffrey D. Wiese\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nMail Stop: E24-455\n1200 New Jersey Ave., SE,\nEast Building, Second Floor\nWashington, DC 20590-0001\nRe: Request for Interpretation for Part 192.281(a):\nDear Mr. Wiese,\nI respectfully request an interpretation for Part 192.281(a) as to whether a special\npermit is required for installation of large diameter fabricated mitered tees and elbows.\nFor pipe sizes 12\" and less, gas operators generally use molded fittings. For pipe\nsizes greater than 12\", molded fittings are not as readily available and gas operators\nneed to use tees and elbows that are fabricated in a factory using several miter joints.\nAt recent industry meetings, there has been some confusion on the interpretation of\nPart 192.281(a):\n§ 192.281 Plastic pipe.\n(a) General. A plastic pipe joint that is joined by solvent cement, adhesive, or heat\nfusion may not be disturbed until it has properly set. Plastic pipe may not be joined by\na threaded joint or miter joint.\nIt is generally understood in the industry that the gas operator may not make miter\njoints in the field. The question is may a gas operator install a fabricated fitting (tee or\nell) containing miter joints if the fitting was made in a factory, and may the gas\noperator install that miter fitting without the need for a special permit?\n\n<<<PAGE 4>>>\n\nSome have the opinion that a special permit is not required because the fabricated\nmiter fitting is made in a factory. This appears to be the interpretation of DOT in 1979\nbased on a letter from Cesar De Leon to Paul Petro - see Attachment A.\nOthers have the opinion that a special permit is required because, even though the\nfabricated miter fitting is made in a factory, it is not made in accordance with a product\nstandard that is referenced in Part 192.\nOur key question is whether or not a special permit is required for a gas operator to\ninstall fabricated mitered tees and elbows that are made in a factory. Thank you.\nRespectfully,\nDr. Gene Palermo\nPalermo Plastics Pipe (P3) Consulting\n654 Watershaw Drive\nFriendsville, TN 37737\n865-995-1156 (Ph)\ngpalermo@plasticspipe.com\nCC: John Gale\nPHP-30\n\n<<<PAGE 5>>>\n\nAttachment A\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nWASktNG'tON. D.C. 20!580\nI!III:PI:R TOt\nSEP 2 5 nr-\nMr. P. P .. Petro\nDirector - Technical Services\n3240 North Mannheim Road\nFranklin Park, minois 60131\nDear Mr. Petro;\nThis reponds to your letter of July 6, 1979, asking if the rule in 49 CFR\n192.28I(a), stating that 11plastic pipe may not be joined by a threaded joint or\nmiter joint,\" applies to the manufacture ot fittings in a plant.\nAs indicated by Section 192.21l(b), neither section 192.281 nor any of the other\nprovisions of Subpart F concerning the joining of materials apply to joining\nthat is performed during the manufacture of pipe or components (including\nfittings). The regulations do apply to any joining of pipe or components that\noccurs !or gas pipeline transportation purposes outside the manufacturing\nfactory. Such joining is normally performed at·a pipeline construction site or\nin fabrication shops •\n..","truncated":false,"body_characters":7385}