{"operation":"document","citation":"PI-72-0100","title":"Fisher Controls Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-01-21","effective_on":null,"summary":"PI-72-0100 response to Fisher Controls Company concerning 192.195.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/g72-01-21_StAmand_192.195-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-72-0100\nJanuary 21, 1972\nMr. Frank St. Amand\nAssistant Sales Manager\nFisher Controls Company\nMarshalltown, Iowa 50158\nDear Mr. St. Amand:\nIn response to your letter of December 20, 1971, requesting an interpretation of Section 192.195 Protection Against\nAccidental Overpressuring, we offer the following:\nQuestion: (Paraphrased) Is there any intent in 192.195 to limit the use of some types of overpressure protective\ndevices that were previously permitted under certain conditions under the interim standards (B31.8) such as relief,\nmonitoring, rupture discs, shut-off and series regulation?\nAnswer: Except as specifically provided for in Section 192.195, there is no intent to limit the type of overpressure\nprotection device that an operator may use. The operator is free to choose the device, including those referenced by\nyou, that will best suit his situation so long as it complies with applicable requirements of Part 192.\nIf you have further question, please advise.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nFisher Controls Company\nMarshalltown, Iowa 50158\nDecember 20, 1971\nSecretary of Transportation\n400 Sixth St. S.W.\nWashington, D. C.\nAttention: Mr. Joseph C. Caldwell Acting Director\nOffice of Pipeline Safety\nDear Mr. Caldwell:\nThe general requirement in the Minimum Federal Standards under 192.195, Protection Again Accidental Overpressuring,\nis a performance standard. The previous guideline for gas industry engineers was Section 845 of the B31.8 Code,\nspecifically, Paragraphs 845.212, 845.222, and 845.23. With certain qualifications, these areas allowed overpressure\nprotection by relief, monitoring, rupture discs, shut-off and series regulation.\nThe question which we have received from some of our customers and which we would like to ask you is, \"Is there any\nintent in 192.195 to limit the use of any of these types of overpressure protection, or are they all still acceptable, as long\nas they meet the performance as required under the minimum Federal Standards?\"\nVery truly yours\nFISHER CONTROLS COMPANY\nFrank St. Amand\nAssistant Sales Manager","truncated":false,"body_characters":2155}