{"operation":"document","citation":"PI-72-037","title":"Kerotest Manufacturing Corp — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-08-14","effective_on":null,"summary":"PI-72-037 response to Kerotest Manufacturing Corp concerning 192.455.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-037.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-037.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-037","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72037.pdf","body":"<<<PAGE 1>>>\n\nAugust 14, 1972\nMr. Alban T. Russell\nVice President - Marketing\nKerotest Manufacturing Corp.\n2525 Liberty Avenue\nPittsburgh, Pennsylvania 15222\nDear Mr. Russell:\nWe have reviewed the request in your letter of August 4, 1972, for a determination as to the\npossible need for cathodic protection of the galvanized steel sheath used as a protective shield\nover your plastic service riser assembly.\nWe find that no cathodic protection is required for this protective steel sheath, because the sheath\nis not considered part of a pipeline as that term is defined in Section 192.3 of the Federal safety\nstandards.\nThank you for your interest. We trust this answers your question satisfactorily.\nSincerely,\n\\signed\\\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\455\\72-08-14\n1\n\n<<<PAGE 2>>>\n\nKEROTEST MANUFACTURING CORP.\nAugust 4, 1972\nMr. J. C. Caldwell\nDirector Office of Pipeline Safety\nDepartment of Transportation\n400 6th St. S.W.\nWashington, D.C. 20024\nGentlemen:\nThe purpose of this letter is to request a specific clarification and interpretation of the Code of\nFederal Regulations specifically with respect to a product manufactured by us.\nEnclosed is Kerotest drawing number D-9994X01 titled \"Riser Assembly for use with 1/2\" IPS\npolyethylene service lines\". Drawings, test results, and actual samples of this product were\nreviewed personally by your Mr. Lance Heverly and Mr. Paul Corey on August 2, 1972, when\nMr. Bill Borin of Kerotest and I visited your offices. The question regarding this product and the\nnecessity for the interpretation arose during our discussions with Mr. Corey and Mr. Heverly.\nBriefly, the intended use of the product is as a meter riser of plastic service lines and the key\nfeature is that it provides a way to connect the plastic service line to the meter with no plastic pipe\nabove ground and no steel pipe below ground, thus being consistent with the latest DOT\nregulations and eliminating the necessity for gas companies to use steel meter risers that must be\ncathodically protected and checked on a basis of 10% per year.\nYou will note that the riser assembly is encased in a galvanized steel sheath identified as item 9 -\nconduit on the bill of materials. You will also note that this conduit is secured to the assembly by\nan end plug, item 10 as well as with an epoxy seal at the top where the steel nipple fits into the\nfiberglass riser pipe. The intent of this conduit sheath is to provide protection for the fiberglass\nriser pipe against external damage above ground as well as to provide a measure of rigidity to the\nassembly for ease of handling and installation. This galvanized steel conduit sheath in no way is\ndal\\192\\455\\72-08-14\n2\n\n<<<PAGE 3>>>\n\npressure containing or gas bearing and its presence or absence does not affect the integrity of the\nassembly as a gas bearing element in any way.\nThe specific interpretation we are requesting relates to the definition of \"pipeline\" as found in\nvolume 35 no. 161 part II title 49 section 192.3 page 13258. If the conduit is interpreted to fall\nwithin the definition of pipeline then not only must it be cathodically protected, but is also subject\nto the 10% check. If the conduit is not interpreted to be a \"pipeline\" then it is not subject to the\n10% check and fulfills the design intent of the whole product.\nIt is Kerotest's contention that the conduit does not fall within the definition of a pipeline, but\nrather is a casing or sleeve which had a purpose completely separate from any gas bearing\nconsiderations, even though this conduit is \"attached\" to the actual riser assembly that is gas\nbearing. We cite of your reference the very common practice in the gas distribution industry of\nmaking plastic pipe insertions in old existing steel service lines. In this case the old steel service is\nthen no longer either cathodically protected or checked since it becomes merely the casing for the\nplastic service line.\nWe at Kerotest sincerely feel that our new plastic pipe riser assembly is a product that will\nenhance safety in the gas industry and provide a means for gas companies to minimize risks of\ndanger as well as conform with the intent of the recent DOT regulations. The concept of joining\nthe plastic pipe to a fiberglass riser pipe below ground level thus eliminating the danger of plastic\nabove ground, and then joining the steel nipple to the other end of the fiberglass riser pipe well\nabove ground level thus avoiding the potential corrosion problems of steel below ground is a\nunique and very desirable solution from the viewpoint of both the operating companies and the\nOffice of Pipeline Safety.\nWe are ready to release this product to the industry pending only the interpretation requested in\nthis letter. Therefore, your earliest possible attention to this matter will be greatly appreciated.\nVery sincerely,\nKEROTEST MANUFACTURING CORP.\n\\SIGNED\\\nAlban T. Russell\nVice President - Marketing\ndal\\192\\455\\72-08-14\n3","truncated":false,"body_characters":4961}