# House of Representatives — Pipeline Safety Interpretation - **operation:** document - **citation:** PI-70-0106 - **title:** House of Representatives — Pipeline Safety Interpretation - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 1970-10-14 - **effective on:** Not available - **summary:** PI-70-0106 response to House of Representatives concerning 192.363. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0106.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0106.md - **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0106 - **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1970/g70-10-14_Bush_192.363-nlmx.pdf **body:** <<>> PI-70-0106 October 14 1970 Honorable George Bush House of Representatives Washington, D.C. 20151 Dear Mr. Bush: This is in reply to your communication of September 25, 1970, enclosing a letter from Mr. Guy Edwards, questioning the safety of the installation of a gas line in a hospital in Buna, Texas. Our analysis of the information Mr. Edwards furnished lead us to the conclusion that the gas pipe to the hospital was equipped with a 3-way valve which permitted by-passing the meter and regulator. The opening of this valve caused the incident described. Regulations issued by this Department on August 11, 1970, which become effective November 12, 1970, require that if such a valve is used an additional valve assuring a positive shut-off of gas flow must be installed. This requirement is contained in section 192.363(a), of Title 49 of the Code of Federal regulations. A copy of part 192 is provided for you information. We are sending a copy of your inquiry and this letter to the Texas Railroad Commission which has certified its authority over intrastate lines to this Department under Section 5(a) of the Natural Gas Pipeline Safety Act of 1968. Thank you for your interest in pipeline safety. Sincerely, Joseph C. Caldwell Director, Acting Office of Pipeline Safety <<>> Guy Edwards, Architect 1834 Sixteenth Street Port Arthur, Texas 77640 September 11, 1970 Richard T. Nixon, President White House Washington, D. C. Dear Mr. President: A situation has occurred in the past week regarding an installation at a hospital where I, in the past, was the Architect. This condition that exists there, I find on examining a school project on which I am engaged, is similar. I am making reference to a gas pipe line meter installation. In each case, the installation is by different gas companies. I am bringing this to your specific attention because what happened, which I will relate, can happen to every commercial institutional building in the United States and can be more dangerous than even the bombings that are now prevalent. As is custom with a hospital in the state of Texas, a yearly "boiler test" is required by the State Department of Health. On each of the past two years on which this has occurred, the hospital has had physical damage, not the same, and the last which was this past Tuesday was the most violent and potentially the most dangerous. The "boiler test", when made, must be made in the following manner. The gas company representative must be present and the plumber retained by the hospital must also be present. Such an occasion calls for the plumber to instruct the gas company to turn off the gas. The plumber then proceeds to check all gas connections within the building. But this is where part of the hazard begins. The above information was passed to the gas company representative, who turned off the gas going through the regulator which feeds the building; but somehow he also turned another valve, which instead of removing gas, opened and provided that all of the pressure that the local gas company had on its lines was thus fed into the building. The regulator, which is a requirement on the house side of all gas installations, reduces the line pressure to, in our case, six ounces of gas pressure. What happened, however, by the turning of the wrong valve in the wrong direction, was to push 32 pounds into the lines. What followed was a minor explosion and a flame that quickly became quite intense; but fortunately I had already provided gas only to the kitchen for cooking purposes and the ceiling was a "2 hour" rated ceiling. The next step that followed would make good comedy, but in this case was also a tragedy of errors. Had it not been for the presence of the Hospital Administrator at the scene, my present letter would be far more vivid in details. The steps taken by the Administrator are not important nor is damage important; what is important is this. For reasons that I cannot fathom, the commercial installations – and I have noted above just two - the gas meter installation provides, under normal installations, that the gas flows through a meter and then is reduced by a regulator to a pressure that appliances are capable of receiving; but, and this is the big important thing, at such an installation there is also installed a bypass. This bypass provides no regulator for the gas from the company lines. Here is where the danger exists. Our difficulty at Buna, Texas was one of stupidity. In the words of the gas man "I thought I had turned the gas off." But let's picture any or every gas installation, if this is normal, in the United States where an anarchist or discontented individual, for reasons best known only to him, decides to make a blazing inferno, a demolition project or what have you. It requires only the turning "the right valve the wrong way''. In major cities and in Federal and government institutions, the gas meter is sometimes remote from the building that it provides with service. The service lines travel through tunnels and other concealed or open hallways. So an indi- vidual does not have to be where great security might exist - even the White House - though remotely served by gas. Only a pilot light on a water heater needs to be exposed to the full pressure of the gas line and then even the White House can become a roaring inferno. I pass all the above information along for your decision. I trust that the information can be used to change the installation procedure used by gas companies for I fear no person or no building is safe. I am taking photographs of the two installations which I will forward as soon as I can get them printed. Respectfully yours, Guy Edwards - **truncated:** false - **body characters:** 5705