{"operation":"document","citation":"PI-70-004","title":"American Meter Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1970-10-28","effective_on":null,"summary":"PI-70-004 response to American Meter Company concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1970/PI70004.pdf","body":"<<<PAGE 1>>>\n\nMr. H. F. Kruzan\nChief Engineer Regulators\nAmerican Meter Company\n300 North Gilbert Avenue\nFullerton, California 92633\nDear Mr. Kruzan:\nThank you for you letter of October 28, 1970, requesting an official interpretation of certain\nsections of 49 CFR, Part 192. The interpretation requested are furnished herewith:\nQuestion 1: Section 192.145 and others: Are pressure regulators to be classified as valves?\nAnswer: Generally speaking pressure regulators are valves and as such must meet the general\nrequirements of this section. The requirements of API-6A and API-6D are limited to steel gate\nvalves, plug valves, ball valves and check valves 2\" and larger in size and MSS-SP-52 is limited to\ncast iron gate valves, plug valves and swing check valves 2\" and larger in size. The omission of\nspecification for other types of valves does not exempt them from the general requirements of this\nsection.\nQuestion 2: Section 192.195(b)(1)(2): Distribution System. What is the intent of the special\nrequirement for Distribution Systems? What type of installation will meet this requirement:\nMonitor, Parallel Stand-By Regulator, or What?\nAnswer: The intent of Section 192.195(b). Additional requirement for distribution systems is to\nprevent subjecting a distribution system to pressures above the maximum allowable operating\npressure of the distribution system. For example, this could be accomplished by use of a monitor\ntype of installation, by a series cut in pressure where the pressure ahead of the downstream\nregulator is less than the MAOP or the distribution system or by use of relief or automatic over\npressure shut-offs. The relief or automatic shut-off may be either built in to the regulator or\nseparate units.\nQuestion 3: Section 192.197(a)(6): Please define the term \"Control Line.\" It is synonymous\nwith static line? There are certain pilot loaded pressure regulators that do not require a static line,\nbut do require a pilot inlet supply line. If this line is broken, the regulator will close. An\noverpressure condition cannot be experienced due to breakage of this line. Please comment.\nAnswer: The term \"Control Line\" used in paragraph 192.197(a)(6) is considered synonymous\nwith \"Static Lines.\" This is taken verbatim from the B31.8 - 1968, paragraph 845.51(f). A pilot\njt/dal/192.3\n70-10-28\n\n<<<PAGE 2>>>\n\nsupply line may be necessary to the operation of a pilot controlled regulator but is not considered\nas prohibited by this paragraph.\nQuestion 4: Section 192.197(b): Concerns gas content of materials that could interfere with the\noperation of a service regulator. Question: Does this mean normal content, or is the operator\nresponsible for any abnormal interpretation, this could mean the end of service regulators that are\nnot equipped with an approved type safety device, could it not?\nAnswer: In Section 192.197(b) the phrase \"or if the gas contains materials that seriously interfere\nwith the operation of service regulators\" is meant only to apply to those conditions that can be\nreasonably anticipated. As examples:\na. Some gases being distributed may contain excessive amounts of sulfur compounds.\nb. Systems that were formerly operated on manufactured gas may contain tars, oils and dust.\nc. If new lines are not cleaned before being placed in service they may contain foreign\nmaterials that were introduced during construction.\nQuestion 5: Section 192.197(a)(1): Paragraph specifies a regulator \"capable\" of reducing\ndistribution pressure, etc. If such a regulator also has the capability of being adjusted for higher\npressures, does this mean that it doesn't meet the requirements of this paragraph?\nAnswer: In Section 192.197(a)(1) the phrase \"cable of reducing distribution line pressure to\npressures recommended for household appliances\" is in no way a restriction on the capability that\nmay be designed into a regulator.\nQuestion 6: Section 192.201(c) and Others: The deletion of 2 psig W.P. so as to conform to\n\"performance-type\" specifications, leaves interpretation of \"safe pressure\" wide open. There will\nundoubtedly be many opinions as to the proper pressure limitation. On what basis will DOT\ndetermine compliance?\nAnswer: The phrase \"the safe operating pressure for any connected and properly adjusted gas\nutilization equipment\" in Section 192.201(c) is intended to place the burden on the operator to\nprevent unsafe conditions. There are some appliances that may be adjusted for normal operation\nat 4 to 6 inches water column that would be dangerous with a 1 1/2 to 2 psig inlet while some\nothers would take 4 to 5 psig and be safe. The operator must determine the maximum safe\noperating pressure and install appropriate relief devices.\njt/dal/192.3\n70-10-28","truncated":false,"body_characters":4713}