{"operation":"document","citation":"PI-17-0018","title":"Alabama Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-07-31","effective_on":null,"summary":"PI-17-0018 response to Alabama Public Service Commission concerning 192.727.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/58911/alabama-pi-17-0018-07-31-2018-part-192727.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\nJUL 3 1 2018\n1200 New Jersey Avenue SE\nWashington DC 20590\nMr. Wallace R. Jones\nDirector, Gas Pipeline Safety\nAlabama Public Service Commission\nP.O. Box 304260\nMontgomery, AL 36130\nDear Mr. Jones:\nIn an October 1 7, 201 7, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested an\ninterpretation regarding the abandonment or deactivation of a service line in§ 192.727(d).\nYou provided the following information.\nAfter reviewing previous written interpretations on the PHMSA website and on\nWinDOT, questions have been brought forth regarding proper enforcement of this\nsection; if an operator disconnects the piping (such as removing the meter) and also\nincorporates a locking or sealing device (options (1) and/or (2)), must both ends of the\npipe be sealed? Since the language in the rule states that \"one of the following must be\ncomplied with\" would the operator be fulfilling the obligations of this section if option (1)\nor (2) is adhered to, and the meter is removed but both ends of the pipe are not sealed?\nAlso, you referenced the following:\nThe following was found on WinDOT as interpretation 192.727 12:\nJanuary 29, 1985\nTalked to Mel Judah on 727 removal off meters and he agrees that when meter is pulled\nthat both ends must be sealed even though valve may be locked.\n1/29/85\nNOTE: Need to write for interpretation to incorporate in file.\nAs you noted, there is no formal interpretation referencing the above \"NOTE\" in WinDOT or on\nthe official PHMSA website, and the January 29, 1985 note did not contain an interpretation.\nTherefore, you requested an interpretation of the§ 192.727(d) requirements.\nSection 192.727(d) states (emphasis added):\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the fonn 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\n( d) Whenever service to a customer is discontinued, one of the following must be\ncomplied with:\n(1) The valve that is closed to prevent the flow of gas to the customer must be provided\nwith a locking device or other means designed to prevent the opening of the valve by\npersons other than those authorized by the operator.\n(2) A mechanical device or fitting that will prevent the flow of gas must be installed in\nthe service line or in the meter assembly.\n(3) The customer's piping must be physically disconnected from the gas supply and the\nopen pipe ends sealed.\nBased on the language of§ 192.727(d), an operator can use any of the three methods to\ndeactivate a service line from a customer line connection. If an operator closes and locks a valve\nto prevent the flow of gas in accordance with§ 192.727(d)(l), the operator is not also required to\nphysically disconnect the pipe from the gas supply under§ 192.727(d)(3). If, however, the\noperator does not close and lock a valve preventing the flow of gas to the customer, the operator\nmust physically disconnect the customer's piping and seal the open ends or install a mechanical\ndevice or fitting that will prevent the flow of gas. An operator may use more than one method,\nbut must fully comply with at least one of the methods that it chooses. An operator is expected\nto perform any deactivation activities in a manner that ensures the safety of the pipeline and that\ncomplies with its operations and maintenance procedures under§ 192.605.\nAs to your second question whether both ends of the service pipe need to be sealed after the\nmeter is removed, if the operator incorporates a locking or sealing device, this is considered\nphysically disconnecting the piping and, therefore, the open ends must be sealed if the operator\nintends to comply with§ 192.727(d)(3). As noted above, if the operator complies with\n§ 192.727(d)(l), the operator is not also required to comply with § 192.727(d)(3). Please be\nadvised that when physically disconnecting pipe, sealing both ends (service line and customer\nline) of the pipe protects against leaks or unintentional opening of any isolation valves from the\nservice line. It also keeps both the service and customer lines from getting moisture and debris\nin the pipe that could hinder the safety of future gas deliver service to the customer.\nlfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written 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\n,!,0C1232017\nSTATE OF ALABAMA\nPUBLIC SERVICE COMMISSION\nP.O. BOX 304260\nMONTGOMERY, ALABAMA 36130\nTWINKLE ANDRESS CAVANAUGH, PRESIDENT\nJEREMY H. ODEN, ASSOCIATE COMMISSIONER\nCHRIS \"CHIP BEEKER, JR., ASSOCIATE COMMISSIONER\nJOHN A. GARNER, EXECUTIVE DIRECTOR\nOctober 17, 2017\nVia Certified Mail, Return Receipt Requested\nMr. John A. Gale, Director\nOffice of Standards and Rulemaking (PHP-30)\nPHMSA, U.S. Department of Transportation\n1200 New Jersey Avenue SE\nWashington, DC 20590-000 1\nRE: Formal Interpretation of 49 CFR Part 192, §192.727(d)\nDear Mr. Gale:\nThis is a request for a formal interpretation of 49 CFR Part 192, § 192.727(d) which states:\n(d) Whenever service to a customer is discontinued, one ofthefollowing must be complied with:\n(1) The valve that is closed to prevent the flow ofgas to the customer must be provided with a\nlocking device or other means designed to prevent the opening of the valve by persons other than\nthose authorized by the operator.\n(2) A mechanical device or fitting that will prevent the flow ofgas must be installed in the\nservice line or in the meter assembly.\n(3) The customer s' piping must be physically disconnectedfrom the gas supply and the open\npipe ends sealed.\nAfter reviewing previous written interpretations on the PHMSA website and on WinDOT,\nquestions have been brought forth regarding proper enforcement of this section; if an operator\ndisconnects the piping (such as removing the meter) and also incorporates a locking or sealing device\n(options (1) andlor (2)), must both ends of the pipe be sealed? Since the language in the rule states\nthat \"one ofthe following must be complied with\" would the operator be fulfilling the obligations of\nthis section if option (1) or (2) is adhered to, and the meter is removed but both ends of the pipe are\nnot sealed?\n\n<<<PAGE 4>>>\n\nMr. John A. Gale\nOctober 17, 2017\nPage 2\nThe following was found on WinDOT as interpretation 192.727 12:\nJanuary 29, 1985\nTalked to Mel Judah on 727 removal off meters and he agrees that when meter is pulled that\nboth ends must be sealed even though valve may be locked.\n1/29/85\nNOTE: Need to write for interpretation to incorporate in file.\nThere is no formal interpretation referencing this note in WinDOT or on the official PHMSA website.\nTherefore, this office is now requesting a formal written interpretation for enforcement of this\nspecific section of the code.\nSincerely,\nWallace R. Jones, ,Jir tor\nGas Pipeline Safe","truncated":false,"body_characters":7827}