Houston Natural Gas Corporation — Pipeline Safety Interpretation

Page 1PI-71-0108 Office of the Secretary of Transportation Washington, D.C. 20590 May 25, 1971 Mr. Raymond R. Smith, P.E. Chief Engineer Houston Natural Gas Corporation 1200 Travis, Box 1188 Houston, Texas 77001 Dear Mr. Smith: This is in reply to your letter of March 10, 1971, concerning the requirements of 49 CFR, Section 192.363(c) for tamper- proof service line valves. We interpret this section to also permit the use of a locking device on the valve, or a locked enclosure such as a fence or building around the valve, as a means of meeting the requirement "to minimize the possibility of removal of the core of the valve with other than specialized tools". Therefore, in order to comply with the regulations you must use the above described or similar methods of protection. Sincerely, Joseph C. Caldwell Acting Director Office of Pipeline Safety#

Page 2Houston Natural Gas Corporation Houston Natural Gas Building 1200 Travis Box 1188 Houston, Texas 77001 March 10, 1971 Mr. Joseph C. Caldwell Acting Director Office of Pipeline Safety Department of Transportation 400 6th Street, S.W. Washington, D.C. 20590 Reference: OPS - Minimum Standards - August 12, 1970 § 192.363 (c) Service Lines: Valve Requirements Dear Mr. Caldwell: Under above referenced regulations all service line valves installed after March 12, 1971 are to be of tamper-proof classification. To date, Houston Natural Gas Corporation has been able to acquire tamper-proof service valves in all required sizes except 3/4". Suppliers have notified us that the 3/4" tamper-proof valves will not be available for at least 4-to-6 weeks. Therefore, until we are able to acquire a supply of 3/4" tamper-proof service line valves we will continue to use our present stock of-3/47 valves. Every effort will be made to acquire the tamper-proof valves at the earliest date. Yours very truly, Houston Natural Gas Corp. Raymond R. Smith, P.E. Chief Engineer#