American Meter Company — Pipeline Safety Interpretation

Page 1PI-70-0112 December 29, 1970 Mr. Giles M. Crabtree, Product Engineer American Meter Company 13500 Philmont Avenue Philadelphia, Pennsylvania 19116 Dear Mr. Crabtree: This refers to your letters of November 16 and December 8, 1970 to Mr, Frank Fulton of the Office of Pipeline Safety of this Department, concerning needle valves manufactured by your company. Because liquid pipelines engaged in interstate commerce are under jurisdiction of the Federal Railroad Administration, your letters were referred to this Bureau for reply. A review has been made of your Bulletin 420.2 in which the needle valves in question are described. It is noted that the valves are used for pipe sizes 1/8" through 1/2" on measurement gages and various control mechanisms. Obviously, valves of those sizes would be external to main line pipe, and would not be used to control the flow of a product moving in interstate commerce. Therefore, the provisions of Section 195.116 of the regulations governing the transportation of liquids by pipeline do not apply to valves as described in Bulletin 420.2 Sincerely yours, Mac E. Rogers Director Bureau of Railroad Safety#

Page 2December 10, 1970 TSA-30 Request for Interpretation of Section 195.116 to Answer Inquiry Submitted by American Meter Company Acting Director Office of Pipeline Safety Director, Bureau of Railroad Safety Federal Railroad Administration Attached is a letter from Mr. Giles M. Crabtree, American Meter Company, dated November 16, 1970. Mr. Crabtree is questioning the applicability of Section 195.116 to needle valves manufactured by the American Meter Company. A copy of my response to Mr. Crabtree is also attached. I believe the best way to respond to Mr. Crabtree is to render an interpretation to the section involved. I would appreciate it if your Office would proceed in this direction and respond to Mr. Crabtree directly. My Office has already reviewed Mr. Crabtree’s letter and the American Meter Company’s Bulletin 420.2, attached to his letter. Valves of the size and type described in Bulletin 420.2 are not normally used to regulate the flow of hazardous commodities moving in transportation, but rather are installed to measure such flow. It is therefore doubtful that these valves would be included within the definition of “pipeline system” contained in Part 195. I would appreciate a copy of your reply to Mr. Crabtree. Signed Joseph C. Caldwell#

Page 3December 8, 1970 American Meter Company 13500 Philmont Avenue Philadelphia, Pennsylvania 19116 Mr. Frank Fulton, Chief Technical Officer Pipeline Safety Division Hazardous Materials Regulations Board U.S. Department of Transportation Washington, D.C. 20590 Dear Mr. Fulton: This is a follow-up on my letter of November 16, to which I have received no response. (A reference copy is attached.) I would appreciate having your judgment on the application of D.O.T. Title 49, part 195, to our needle valve product line as soon as possible. Thank you. Very truly yours, Giles M. Crabtree Product Engineer#

Page 4November 16, 1970 American Meter Company 13500 Philmont Avenue Philadelphia, Pennsylvania 19116 November 16, 1970 Mr. Frank Fulton, Chief Technical Officer Pipeline Safety Division Hazardous Materials Regulations Board U.S. Department of Transportation Washington, D.C. 20590 Dear Mr. Fulton: We have been asked if our needle valve product line complies with D.O.T. Title 49, part 195. In reviewing section 195.116, it appears we do not meet the requirements of e (position indicator) and f3, f4 (material and size marking). We would like to question whether these requirements are applicable to our needle valve products since position indicators are rarely, if ever, incorporated in this valve type. The valves in question are used on pipeline systems in pressure sensing lines for flow and pressure measurement devices. Attached is a copy of our bulletin 420.2 describing the needle valves. We would appreciate having your opinion as quickly as possible. Very truly yours, Giles M. Crabtree Product Engineer#

Page 5December 8, 1970 Mr. Giles M. Crabtree Product Engineer American Meter Company 13500 Philmont Avenue Philadelphia, Pennsylvania 19116 Dear Mr. Crabtree; This is in answer to your letter of November 16, 1970, requesting our opinion as to the applicability of Section 195.116 to needle valves manufactured by the American Meter Company. The Federal Railroad Administration exercises statutory responsibility over the safety of liquid pipelines and administers the safety regulations contained in Part 195. I am forwarding your letter to the Director, Bureau of Railroad Safety, Federal Railroad Administration, requesting an interpretation of the regulations in order to answer your specific questions. Either the Director or myself will respond to you after an interpretation has been made. Sincerely, Joseph C. Caldwell Director, Acting Office of Pipeline Safety#