{"operation":"document","citation":"PI-72-0118","title":"Sprague Meter Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-12-22","effective_on":null,"summary":"PI-72-0118 response to Sprague Meter Company concerning 192.197.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-0118.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-0118.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-0118","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/g72-12-22_Berghegger_192.197-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-72-0118\nDecember 22, 1972\nMr. Howard W. Berghegger\nManager-Technical Services\nSprague Meter Company\n35 South Avenue\nBridgeport, Connecticut 06601\nDear Mr. Berghegger:\nThis is in reply to your letter of November 17, 1972, concerning constant loaded regulators which you manufacture. You\nask for confirmation of your understanding that the inlet pressure line of such a regulator is not classed as a control line.\nSection 192.197 (a) (6) of the federal regulations (49 CFR §192.197 (a) (6) states that where the maximum actual\noperating pressure of a distribution system is under 60 p.s.i.g., no other pressure limiting device is required if the system\nhas a service regulator which, among other characteristics, is self-contained with no external static or control lines. You\nquestion now, in effect, whether the inlet pressure line connecting the two valve bodies of your constant loaded\nregulator would be acceptable under the regulation.\nYour understanding is correct. Even though the inlet pressure line is a pilot supply line which may be necessary to the\noperation of the regulator, it is not classed as an external static or control line for purposes of §192.197(a)(6).\nIf we may be of further assists in this matter, please call on us.\nSincerely,\nSIGNED\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nSprague Meter Company\n35 South Avenue\nBridgeport, Connecticut 06601\nNovember 17, 1972\nMr. Paul Cory\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D. C. 20590\nDear Mr. Cory:\nDuring the Appalachian Gas Measurement Short Course in Morgantown, West Virginia last August, you told Mr. George\nHughes that, in your opinion, D.O.T. did not consider the inlet pressure line connecting the two valve bodies of our CL\n(constant loaded) regulator as a pilot operated regulator control line.\nDue to the various utility companies’ interpretation of the code, many of our customers will not use the CL regulators, as\nthey feel the line is classed as a \"control line.\"\nAttached is literature describing the CL-34, CL-31, and CL-231 regulators. Will you please review and give us a letter\nstating the function of the inlet pressure line is not classed as a pilot operated control line, if this is your decision.\nYour cooperation and attention to this urgent matter will be greatly appreciated.\nSincerely,\nHoward W. Berghegger\nManager – Technical Services","truncated":false,"body_characters":2405}