{"operation":"document","citation":"PI-70-0112","title":"American Meter Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1970-12-10","effective_on":null,"summary":"PI-70-0112 response to American Meter Company concerning 195.116.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0112.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0112.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0112","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1970/g70-12-10_Crabtree_195.116-DBx.pdf","body":"<<<PAGE 1>>>\n\nPI-70-0112\nDecember 29, 1970\nMr. Giles M. Crabtree, Product Engineer\nAmerican Meter Company\n13500 Philmont Avenue\nPhiladelphia, Pennsylvania 19116\nDear Mr. Crabtree:\nThis refers to your letters of November 16 and December 8, 1970 to Mr, Frank Fulton of the Office of Pipeline Safety of this\nDepartment, concerning needle valves manufactured by your company. Because liquid pipelines engaged in interstate\ncommerce are under jurisdiction of the Federal Railroad Administration, your letters were referred to this Bureau for reply.\nA review has been made of your Bulletin 420.2 in which the needle valves in question are described. It is noted that the\nvalves are used for pipe sizes 1/8\" through 1/2\" on measurement gages and various control mechanisms. Obviously, valves\nof those sizes would be external to main line pipe, and would not be used to control the flow of a product moving in\ninterstate commerce. Therefore, the provisions of Section 195.116 of the regulations governing the transportation of liquids\nby pipeline do not apply to valves as described in Bulletin 420.2\nSincerely yours,\nMac E. Rogers\nDirector\nBureau of Railroad Safety\n\n<<<PAGE 2>>>\n\nDecember 10, 1970\nTSA-30\nRequest for Interpretation of\nSection 195.116 to Answer Inquiry\nSubmitted by American Meter Company\nActing Director\nOffice of Pipeline Safety\nDirector, Bureau of Railroad Safety\nFederal Railroad Administration\nAttached is a letter from Mr. Giles M. Crabtree, American Meter Company, dated November 16, 1970. Mr.\nCrabtree is questioning the applicability of Section 195.116 to needle valves manufactured by the American\nMeter Company. A copy of my response to Mr. Crabtree is also attached.\nI believe the best way to respond to Mr. Crabtree is to render an interpretation to the section involved. I\nwould appreciate it if your Office would proceed in this direction and respond to Mr. Crabtree directly.\nMy Office has already reviewed Mr. Crabtree’s letter and the American Meter Company’s Bulletin 420.2,\nattached to his letter. Valves of the size and type described in Bulletin 420.2 are not normally used to regulate\nthe flow of hazardous commodities moving in transportation, but rather are installed to measure such flow. It\nis therefore doubtful that these valves would be included within the definition of “pipeline system” contained\nin Part 195.\nI would appreciate a copy of your reply to Mr. Crabtree.\nSigned\nJoseph C. Caldwell\n\n<<<PAGE 3>>>\n\nDecember 8, 1970\nAmerican Meter Company\n13500 Philmont Avenue\nPhiladelphia, Pennsylvania 19116\nMr. Frank Fulton, Chief Technical Officer\nPipeline Safety Division\nHazardous Materials Regulations Board\nU.S. Department of Transportation\nWashington, D.C. 20590\nDear Mr. Fulton:\nThis is a follow-up on my letter of November 16, to which I have received no response. (A reference copy is\nattached.)\nI would appreciate having your judgment on the application of D.O.T. Title 49, part 195, to our needle valve\nproduct line as soon as possible. Thank you.\nVery truly yours,\nGiles M. Crabtree\nProduct Engineer\n\n<<<PAGE 4>>>\n\nNovember 16, 1970\nAmerican Meter Company\n13500 Philmont Avenue\nPhiladelphia, Pennsylvania 19116\nNovember 16, 1970\nMr. Frank Fulton, Chief Technical Officer\nPipeline Safety Division\nHazardous Materials Regulations Board\nU.S. Department of Transportation\nWashington, D.C. 20590\nDear Mr. Fulton:\nWe have been asked if our needle valve product line complies with D.O.T. Title 49, part 195. In reviewing\nsection 195.116, it appears we do not meet the requirements of e (position indicator) and f3, f4 (material and\nsize marking).\nWe would like to question whether these requirements are applicable to our needle valve products since\nposition indicators are rarely, if ever, incorporated in this valve type.\nThe valves in question are used on pipeline systems in pressure sensing lines for flow and pressure\nmeasurement devices. Attached is a copy of our bulletin 420.2 describing the needle valves.\nWe would appreciate having your opinion as quickly as possible.\nVery truly yours,\nGiles M. Crabtree\nProduct Engineer\n\n<<<PAGE 5>>>\n\nDecember 8, 1970\nMr. Giles M. Crabtree\nProduct Engineer\nAmerican Meter Company\n13500 Philmont Avenue\nPhiladelphia, Pennsylvania 19116\nDear Mr. Crabtree;\nThis is in answer to your letter of November 16, 1970, requesting our opinion as to the applicability of Section\n195.116 to needle valves manufactured by the American Meter Company.\nThe Federal Railroad Administration exercises statutory responsibility over the safety of liquid pipelines and\nadministers the safety regulations contained in Part 195.\nI am forwarding your letter to the Director, Bureau of Railroad Safety, Federal Railroad Administration,\nrequesting an interpretation of the regulations in order to answer your specific questions. Either the Director\nor myself will respond to you after an interpretation has been made.\nSincerely,\nJoseph C. Caldwell\nDirector, Acting\nOffice of Pipeline Safety","truncated":false,"body_characters":4953}