{"operation":"document","citation":"PI-71-014","title":"Rockwell Manufacturing Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-02-05","effective_on":null,"summary":"PI-71-014 response to Rockwell Manufacturing Company concerning 192.145, 192.363.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71014.pdf","body":"<<<PAGE 1>>>\n\nMr. B. J. Milleville, Vice President\nValve Engineering & Research\nRockwell Manufacturing Company\n400 N. Lexington Avenue\nPittsburgh, Pennsylvania 15208\nDear Mr. Milleville:\nThis is in reply to your letter of December 15, 1970, addressed to Mr. Frank Fulton and your\nletter of December 14, 1970, addressed to Mr. William Broderick. The first requested an\ninterpretation of Section 192.363(c). You state, \"one major subject for consideration is the intent\nof the term \"specialized tools.\" Is it intended simply to require something beyond a screwdriver\nor pair of pliers? , or do we really mean that if a tool you can buy at Sears will do it, it's not\nacceptable?\n\"Specialized tools\" refer to tools which are designed specifically for the removal of a service line\nvalve core and which would serve no other purpose. The requirement presumes that such a tool\nwould not normally be in the hands of anyone other than a gas company employee or other\nauthorized persons. The ANSI B31.8 Committee considered this requirement important enough\nto have made it part of their Code (Section 849.12(d) and it therefore was contained in the\nInterim Federal Safety Standards for two years. In establishing the minimum standards of Part\n192, we saw no reason for deleting it. We recognize that \"tamperproof\" valves are not presently\nmanufactured in sizes over 2 inches. However, we consider a locking device on the valve or a\nlocked enclosure such as a fence or building around the valve as meeting the requirement to\n\"minimize the possibility of removal of the core of the valve with other than specialized tools.\"\nIn your letter of December 14, 1970, to Mr. Broderick you state, \"Paragraph 192.145(2)(d) (in\nVolume 35 Number 161 of the Federal Register) provides that\" no valve having pressure\ncontaining parts made of ductile iron may be used in gas pipe components of compressor stations.\nMany valves in very general use have cast iron (not ductile iron) plugs or balls in combination\nwith steel shell components (bodies, covers). Can it be confirmed that such construction is\nacceptable?\nDB\nC:\\WP51\\INTERPRT\\192\\363\\71-02-05\n1\n\n<<<PAGE 2>>>\n\nIt was our intent in Section 192.145 to adopt as requirements those contained in paragraph\n831.11(c) of the ANSI B31.8 Code (1968 edition), which permits the use of cast iron plugs or\nballs combination with steel shell components.\nIf you have further questions, do not hesitate to ask.\nSincerely,\n/signed/\nJoseph C. Caldwell, Director\nDB\nC:\\WP51\\INTERPRT\\192\\363\\71-02-05\n2","truncated":false,"body_characters":2517}