{"operation":"document","citation":"PI-71-0121","title":"Cyclonics, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-12-03","effective_on":null,"summary":"PI-71-0121 response to Cyclonics, Inc. concerning 192.501.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0121.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0121.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0121","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/g71-12-03_Roberts_192.501-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-71-0121\nDecember 3, 1971\nMr. W. C. Roberts\nCyclonics, Inc.\n711 West Smith Road\nMedina, Ohio 44256\nDear Mr. Roberts:\nYour letter of October 20, 1971 reflects the regulations as they were originally proposed by Notice of Proposed\nRulemaking procedure. Enclosed is a copy of the regulations and amendments as promulgated that are now in effect.\nIn reply to your questions:\nQuestion 1: is there anything in OPS rules that would preclude the use of CO2 as a testing medium in connection with\nleak testing under the act?\nThe use of inert CO2 gas for testing is permissible in accordance with Section 192.503 (b) and (c).\nQuestion 2: It is our understanding that the new regulations provide for periodic testing of existing lines every five years\nas well as newly installed lines. Is this correct?\nPeriodic testing is not required in the final standards. General initial test requirements are covered in Subpart J,\nuprating test requirements are coved in Subpart k, and test requirements where a change in class location is involved\nare covered in section 192.611.\nQuestion 3: It is our understanding that the new regulations are not satisfied by the use of vapor sniffing equipment, but\nthat an internal test of the pipe under 90 pound pressure is required. May we have your comments?\nSubpart J covers the test requirements. Any method that will discover all potentially hazardous leaks in any segment of\npipeline being tested may be used.\nQuestion 4: Who is charged with enforcement?\nSince Louisiana and New Jersey are not presently cooperating with the Department under Section 5 of the Natural Gas\nPipeline Safety Act, all intrastate gas facilities in those States are a direct enforcement responsibility of this office. At the\npresent time this office also has direct safety enforcement responsibility for municipal gas systems in California, Georgia,\nKentucky, Missouri, Ohio, Pennsylvania and Virginia. Except for these municipal systems, a few privately owned gas\nfacilities in some States, and some LP gas systems that are subject to the act, certain State agencies have safety\njurisdiction over all intrastate gas facilities. In Minnesota, Nebraska, and South Dakota, the State agency is the State Fire\nMarshal. In all the other States including the District of Columbia and Puerto Rico, the Public Service Commission\n(sometimes called the Railroad Commission or Utilities Commission) has safety jurisdiction over intrastate facilities.\nQuestion 5: Does your office interest itself in the selection or specification of test equipment? If so, we would welcome\nthe opportunity to have your office inspect and evaluate the equipment of our client.\nThis office does not make any recommendations with regard to the use of proprietary equipment.\nThank you for your interest in our safety program.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nCyclonics, inc\n711 West Smith Road\nMedina, Ohio 44256\nOctober 20, 1971\nMr. W. C. Jennings, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D. C.\nDear Mr. Jennings:\nOne of our clients has under development and test a new device designed to facilitate the testing of gas service lines\nunder the new high pressure testing requirements of the Pipe Line Safety Act.\nThis was developed with the active collaboration of several officials of one of the large utilities in this area and in fact a\nnumber of these devices is currently in use. I am attaching herewith a photo and description of the product.\nWe are retained to investigate the marketing possibilities of this unit and would appreciate your response to the\nfollowing questions at your earliest convenience.\n1. Is there anything in OPS rules that would preclude the use of CO2 as a testing medium in connection\nwith leak testing under the act?\n2. It is our understanding that the new regulations provide for periodic testing of existing lines every five\nyears as well as newly installed lines. Is this correct?\n3. It is our understanding that the new regulations are not satisfied by the use of vapor sniffing equipment,\nbut that an internal test of the pipe under 90 pound pressure is required. May we have your comments?\n4. Who is charged with enforcement?\n5. Does your office interest itself in the selection or specification of test equipment? If so, we would\nwelcome the opportunity to have your office inspect and evaluate the equipment of our client.\nAt your earliest convenience will you please forward a copy of the new regulations concerning leak inspection\nprocedures also any other background materials, news releases, etc. which would give us a broader understanding of\nthis area of interest.\nSincerely,\nMarketing Services Division\nW. C. Roberts\nGeneral Manager","truncated":false,"body_characters":4773}