Alabama Public Service Commission — Pipeline Safety Interpretation

Page 1U.S. Department ofTransportation Pipeline and Hazardous Materials Safety Administration JUL 3 1 2018 1200 New Jersey Avenue SE Washington DC 20590 Mr. Wallace R. Jones Director, Gas Pipeline Safety Alabama Public Service Commission P.O. Box 304260 Montgomery, AL 36130 Dear Mr. Jones: In an October 1 7, 201 7, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested an interpretation regarding the abandonment or deactivation of a service line in§ 192.727(d). You provided the following information. After reviewing previous written interpretations on the PHMSA website and on WinDOT, questions have been brought forth regarding proper enforcement of this section; if an operator disconnects the piping (such as removing the meter) and also incorporates a locking or sealing device (options (1) and/or (2)), must both ends of the pipe be sealed? Since the language in the rule states that "one of the following must be complied with" would the operator be fulfilling the obligations of this section if option (1) or (2) is adhered to, and the meter is removed but both ends of the pipe are not sealed? Also, you referenced the following: The following was found on WinDOT as interpretation 192.727 12: January 29, 1985 Talked to Mel Judah on 727 removal off meters and he agrees that when meter is pulled that both ends must be sealed even though valve may be locked. 1/29/85 NOTE: Need to write for interpretation to incorporate in file. As you noted, there is no formal interpretation referencing the above "NOTE" in WinDOT or on the official PHMSA website, and the January 29, 1985 note did not contain an interpretation. Therefore, you requested an interpretation of the§ 192.727(d) requirements. Section 192.727(d) states (emphasis added): The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the fonn 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 22 ( d) Whenever service to a customer is discontinued, one of the following must be complied with: (1) The valve that is closed to prevent the flow of gas to the customer must be provided with a locking device or other means designed to prevent the opening of the valve by persons other than those authorized by the operator. (2) A mechanical device or fitting that will prevent the flow of gas must be installed in the service line or in the meter assembly. (3) The customer's piping must be physically disconnected from the gas supply and the open pipe ends sealed. Based on the language of§ 192.727(d), an operator can use any of the three methods to deactivate a service line from a customer line connection. If an operator closes and locks a valve to prevent the flow of gas in accordance with§ 192.727(d)(l), the operator is not also required to physically disconnect the pipe from the gas supply under§ 192.727(d)(3). If, however, the operator does not close and lock a valve preventing the flow of gas to the customer, the operator must physically disconnect the customer's piping and seal the open ends or install a mechanical device or fitting that will prevent the flow of gas. An operator may use more than one method, but must fully comply with at least one of the methods that it chooses. An operator is expected to perform any deactivation activities in a manner that ensures the safety of the pipeline and that complies with its operations and maintenance procedures under§ 192.605. As to your second question whether both ends of the service pipe need to be sealed after the meter is removed, if the operator incorporates a locking or sealing device, this is considered physically disconnecting the piping and, therefore, the open ends must be sealed if the operator intends to comply with§ 192.727(d)(3). As noted above, if the operator complies with § 192.727(d)(l), the operator is not also required to comply with § 192.727(d)(3). Please be advised that when physically disconnecting pipe, sealing both ends (service line and customer line) of the pipe protects against leaks or unintentional opening of any isolation valves from the service line. It also keeps both the service and customer lines from getting moisture and debris in the pipe that could hinder the safety of future gas deliver service to the customer. lfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523. Sincerely, 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 3,!,0C1232017 STATE OF ALABAMA PUBLIC SERVICE COMMISSION P.O. BOX 304260 MONTGOMERY, ALABAMA 36130 TWINKLE ANDRESS CAVANAUGH, PRESIDENT JEREMY H. ODEN, ASSOCIATE COMMISSIONER CHRIS "CHIP BEEKER, JR., ASSOCIATE COMMISSIONER JOHN A. GARNER, EXECUTIVE DIRECTOR October 17, 2017 Via Certified Mail, Return Receipt Requested Mr. John A. Gale, Director Office of Standards and Rulemaking (PHP-30) PHMSA, U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, DC 20590-000 1 RE: Formal Interpretation of 49 CFR Part 192, §192.727(d) Dear Mr. Gale: This is a request for a formal interpretation of 49 CFR Part 192, § 192.727(d) which states: (d) Whenever service to a customer is discontinued, one ofthefollowing must be complied with: (1) The valve that is closed to prevent the flow ofgas to the customer must be provided with a locking device or other means designed to prevent the opening of the valve by persons other than those authorized by the operator. (2) A mechanical device or fitting that will prevent the flow ofgas must be installed in the service line or in the meter assembly. (3) The customer s' piping must be physically disconnectedfrom the gas supply and the open pipe ends sealed. After reviewing previous written interpretations on the PHMSA website and on WinDOT, questions have been brought forth regarding proper enforcement of this section; if an operator disconnects the piping (such as removing the meter) and also incorporates a locking or sealing device (options (1) andlor (2)), must both ends of the pipe be sealed? Since the language in the rule states that "one ofthe following must be complied with" would the operator be fulfilling the obligations of this section if option (1) or (2) is adhered to, and the meter is removed but both ends of the pipe are not sealed?#

Page 4Mr. John A. Gale October 17, 2017 Page 2 The following was found on WinDOT as interpretation 192.727 12: January 29, 1985 Talked to Mel Judah on 727 removal off meters and he agrees that when meter is pulled that both ends must be sealed even though valve may be locked. 1/29/85 NOTE: Need to write for interpretation to incorporate in file. There is no formal interpretation referencing this note in WinDOT or on the official PHMSA website. Therefore, this office is now requesting a formal written interpretation for enforcement of this specific section of the code. Sincerely, Wallace R. Jones, ,Jir tor Gas Pipeline Safe#