{"operation":"document","citation":"PI-15-0007","title":"Rhode Island Division of Public Utilities and Carriers — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-02-10","effective_on":null,"summary":"PI-15-0007 response to Rhode Island Division of Public Utilities and Carriers concerning 192.381.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0007","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2016/PI_150007.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nFEB 10 2016\nMr. Don A. Ledversis\nPipeline Safety Engineer\nRhode Island Division of Public Utilities & Carriers\n89 Jefferson Blvd\nWarwick, RI 02888\nDear Mr. Ledversis:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nSeptember 10, 2015, you requested an interpretation of 49 CFR Part 192. Specifically, you\nasked whether a service line without an excess flow valve, which is damaged by excavation\nactivity, must be replaced with an excess flow valve under the requirement of§ 192.381 ( d).\nSection 192.383(b) discusses the requirements for excess flow valve installation_ as follows:\n§ 192.383 Excess flow valve installation.\n(b) Installation required. An excess flow valve (EFV) installation\nmust comply with the performance standards in § 192.381. The\noperator must install an EFV on any new or replaced service line\nserving a single-family residence after February 12, 20 I 0, unless\none or more of the following conditions is present:\n( 1) The service line does not operate at a pressure of 10 psig or\ngreater throughout the year;\n(2) The operator has prior experience with contaminants in the gas\nstream that could interfere with the EFV's operation or cause loss\nof service to a residence;\n(3) An EFV could interfere with necessary operation or\nmaintenance activities, such as blowing liquids from the line; or\n( 4) An EFV meeting performance standards in § 192.3 81 is not\ncommercially available to the operator.\nWhere none of the conditions listed in § 192.383(b) are present, as discussed in your letter, a\nreplaced service line may require the installation of an excess flow valve. A replaced service\nline is defined, under§ 192.383(a), as \"a gas service line where the fitting that connects the\nservice line to the main is replaced or the piping connected to this fitting is replaced.\"\nFurthermore, pursuant to § 192.383(b), the installation of an excess flow valve must comply with\nthe performance standards in § 192.381, including§ 192.381 (b) which states \"An operator shall\nlocate an excess flow valve as near as practical to the fitting connecting the service line to its\nsource of gas supply.\"\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nWe agree with your understanding that if an excess flow valve is installed, it should be placed as\nnear to the source of gas supply as practical to ensure the excess flow valve protects the\nmaximum length of service line. An excess flow valve is required if the service line from the\nmain to the customer's house, or a segment of service line near the fitting connecting the main to\nthe service line (where an excess flow valve is usually located), is replaced. However, an excess\nflow valve is not required for replacement of short segments of service line far away from the\nmain or source of supply because excess flow valves in those locations may not provide\nexcavation-damage protection.\nIf we can be of further assistance, please contact Tewabe Ase be at 202-366-5523.\nSincere~,\n1l\nohnA. Gale\n. Director, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides wri!ten clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nDIVISION OF PUBLIC UTILITIES AND CARRIERS\n89 Jefferson Blvd. FAX (401) 941-4885\nWarwick, R.I. 02888\n(401) 941-4500\nMr. John Gale September 10, 2015\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave\nSE, 2nd Floor, E22-321\nWashington, D.C. 20590\nRe: Request for Letter of Interpretation\nThe Rhode Island Division of Public Utilities and Carriers (RIDPUC) requests an\ninterpretation of The Pipeline Safety Regulations 49 CFR Part 192.381(d) Service Lines:\nExcess flow valve performance standards which states,\n(d) An operator shall locate an excess flow valve as near as\npractical to the fitting connecting the service line to its source\nof gas supply.\nOur interpretation relates to the particular situation where a gas service line that did not\noriginally have an excess flow installed on it is required to be repaired due to excavation\nactivities damaging the line requiring a section to be cut out and replaced with a new piece\nof pipe. In the particular case where the gas service line did not originally have an excess\nflow valve installed the operator is therefore required to install an excess flow valve if all the\ncriteria are met as described in 49 CFR Part 192.383(b)(1-4) Excess flow valve installation\nwhich states,\nAn excess flow valve must be installed on any new or\nreplaced service line serving a single-family residence after\nFebruary 12, 2010, unless one or more of the following\nconditions is present: (1) The service line does not operate at\na pressure of 10 psig or greater throughout the year; (2) The\n\n<<<PAGE 4>>>\n\noperator has prior experience with contaminants in the gas\nstream that could interfere with the EFV's operation or cause\nloss of service to a residence; (3) An EFV could interfere with\nnecessary operation or maintenance activities, such as\nblowing liquids from the line; or (4) An EFV meeting\nperformance standards in §192.381 is not commercially\navailable to the operator.\nAssuming all the criteria above is met the operator would be required to install an excess\nflow valve to the repaired service line since the cut out pipe section meets the definition of a\nReplaced service line as defined in 49 CFR Part 192.383(a) Excess flow valve installation\nwhich states,\nReplaced service line means a gas service line where the\nfitting that connects the service line to the main is replaced or\nthe piping connected to this fitting is replaced.\nAt this point the operator is required to install the excess flow valve to meet compliance\nwith Part 192.381(d) Service Lines: Excess flow valve performance standards. The Division\ninterprets Part 192.381(d) as requiring the installation of the excess flow valve at the main in\nclose proximity to the fitting connecting the service line to its source of gas supply and not at\nthe point of the excavation damage. For example if the repair is made only several feet\nfrom the foundation wall of the residence the installation of an excess flow valve in such\nclose proximity to the foundation wall would provide very little safety for future excavation\nactivity. The misinterpretation of the word “practical” and the installation the excess flow\nvalve at the point of the excavation damage as a quick fix undermines the true safety\nbenefits of the excess flow valve. Excess flow valves can provide protection to the gas\ncustomer properties from the consequences of a break in the service line.\nThe Division requests a Letter of Interpretation from PHMSA regarding the above issue.\nDon A. Ledversis\nPipeline Safety Engineer\nRhode Island Division of Public Utilities & Carriers\nCC: Thomas Ahern, Administrator, RIDPUC\nJames Lanni, Associate Administrator of Operations and Consumer Affairs, RIDPUC","truncated":false,"body_characters":7880}