{"operation":"document","citation":"PI-70-015","title":"American Meter Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1970-12-04","effective_on":null,"summary":"PI-70-015 response to American Meter Company concerning 192.145, 192.195.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1970/PI70015.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 sections of 49\nCFR, 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 requirements\nof this section. The requirements of API-6A and API-6D are limited to steel gate valves, plug valves, ball\nvalves and check valves 2\" and larger in size and MSS-SP-52 is limited to cast iron gate valves, plug\nvalves and swing check valves 2\" and larger in size. The omission of specification for other types of valves\ndoes not exempt them from the general requirements of this section.\nQuestion 2: Section 192.195(b)(1)(2): Distribution System. What is the intent of the special requirement\nfor Distribution Systems? What type of installation will meet this requirement: Monitor, Parallel Stand-By\nRegulator, or What?\nAnswer: The intent of Section 192.195(b). Additional requirement for distribution systems is to prevent\nsubjecting a distribution system to pressures above the maximum allowable operating pressure of the\ndistribution system. For example, this could be accomplished by use of a monitor type of installation, by a\nseries cut in pressure where the pressure ahead of the downstream regulator is less than the MAOP or the\ndistribution system or by use of relief or automatic over pressure shut-offs. The relief or automatic shut-\noff may be either built in to the regulator or separate units.\nQuestion 3: Section 192.197(a)(6): Please define the term \"Control Line.\" It is synonymous with static\nline? There are certain pilot loaded pressure regulators that do not require a static line, but do require a\npilot inlet supply line. If this line is broken, the regulator will close. An overpressure condition cannot be\nexperienced due to breakage of this line. Please comment.\nAnswer: The term \"Control Line\" used in paragraph 192.197(a)(6) is considered synonymous with \"Static\nLines.\" This is taken verbatim from the B31.8 - 1968, paragraph 845.51(f). A pilot supply line may be\nnecessary to the operation of a pilot controlled regulator but is not considered as prohibited by this\nparagraph.\nQuestion 4: Section 192.197(b): Concerns gas content of materials that could interfere with the operation\nof a service regulator. Question: Does this mean normal content, or is the operator responsible for any\nabnormal interpretation, this could mean the end of service regulators that are not equipped with an\napproved type safety device, could it not?\nDB\nC:\\WP51\\INTERPRT\\192\\195\\70-12-04\n1\n\n<<<PAGE 2>>>\n\nAnswer: In Section 192.197(b) the phrase \"or if the gas contains materials that seriously interfere with the\noperation of service regulators\" is meant only to apply to those conditions that can be reasonably\nanticipated. 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 materials that\nwere introduced during construction.\nQuestion 5: Section 192.197(a)(1): Paragraph specifies a regulator \"capable\" of reducing distribution\npressure, etc. If such a regulator also has the capability of being adjusted for higher pressures, does the\nmean that it doesn't meet the requirements of this paragraph?\nAnswer: In Section 192.197(a)(1) the phrase \"capable of reducing distribution line pressure to pressures\nrecommended for household appliances\" is in no way a restriction on the capability that may be designed\ninto a regulator.\nQuestion: Section 192.201(c) and Others: The deletion of 2 psig W.P. so as to conform to \"performance-\ntype specifications, leaves interpretation of \"safe pressure\" wide open. There will undoubtedly be many\nopinions as to the proper pressure limitation. On what basis will DOT determine compliance?\nAnswer: The phrase \"the safe operating pressure for any connected and properly adjusted gas utilization\nequipment\" in Section 192.201(c) is intended to place the burden on the operator to prevent unsafe\nconditions. There are some appliances that may be adjusted for normal operation at 4 to 6 inches water\ncolumn that would be dangerous with a 1/1/2 to 2 psig inlet while some others would take 4 to 5 psig and\nbe safe. The operator must determine the maximum safe operating pressure and install appropriate relief\ndevices.\nQuestion 7: Section 192.63 Marking of Materials: Please elaborate on this requirement. Examples would\nbe of help. Does this apply to any and all pressure regulators; service, appliance, etc., small and large? Is\nthe intent to identify casting material per ASTM specification, etc., or to identify the complete product with\na given specification?\nAnswer: In Section 192.63 the intention is to require positive identification of the equipment or component\nand thus assure that it is not subjected to operating and conditions exceeding those for which it was\ndesigned. Where the requirements of MSS SP-25 apply they should be followed. Under the definition of\n\"service line\" presently contained in Section 192.3 the standards of Part 192 do not apply downstream of\n192.3 the standards of Part 192 do not apply downstream of the customer's meter, therefore, house piping\nand appliances do not have to be marked.\nDB\nC:\\WP51\\INTERPRT\\192\\195\\70-12-04\n2\n\n<<<PAGE 3>>>\n\nQuestion 8 : Section 192.275(e): May cast iron valves or filters be made with flanges not cast integrally,\nbut assembled to the valve or filter body with retaining rings? Is this requirement different if these cast iron\nvalves or filters are installed in steel pipe?\nAnswer: Section 192.275(e) is a rewording of the B31.8, subparagraph 842.15(d) and clearly requires\nflanges or flanged joints to be integrally cast with the pipe, valve or fitting. This does not prohibit the\nconnection of cast iron flanges to flanges of other materials.\nQuestion 9: Section 192.509(b): Are \"conversion\" operations affected by this requirement, or are they\nwholly governed by Subpart K - Uprating?\nAnswer: It is assumed that by the term \"conversion\" you are referring to increasing operating pressure on a\ngas system from low pressure (see definition in Section 192.3). Section 192.509(b) applies to new\nconstruction and does not apply to uprating.\nQuestion 10: Section 192.145(c)(2) Ductile Iron: Is welding of any type an acceptable method of casting\nsalvage? In our area, foundry suppliers have been quite successful in this procedure.\nAnswer: Section 192.145(c)(2) is taken directly from the B31.8, 1968 edition, paragraph 831.11(b) and\nprohibits such welding. This may be considered for a possible proposal of rulemaking.\nIf your have further questions, do not hesitate to ask.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector, Acting\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\195\\70-12-04\n3","truncated":false,"body_characters":7157}