{"operation":"document","citation":"PI-74-005","title":"Alabama Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-01-29","effective_on":null,"summary":"PI-74-005 response to Alabama Public Service Commission concerning 192.123, 192.375.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/PI74005.pdf","body":"<<<PAGE 1>>>\n\nJan 25 1974\nMr. Larry E. Waldrop\nAlabama Public Service Commission\nP.O. Box 991\nMontgomery, AL 36102\nDear Mr. Waldrop:\nYour letter to Mr. Frank Fulton dated January 7, 1974, asked if certain service risers made for use\nwith plastic service piping would meet Office of Pipeline Safety's regulations. You specifically\nnamed items made by Perfection Corporation and Kerotest Manufacturing Corporation, both of\nwhich consist of a metal sheath used as a protective shield over a plastic service riser assembly.\nFrom the information provided it appears that if these risers are installed so that all the below\nground gas containing materials are plastic, no cathodic protection is required. The metallic\nsheath is not considered part of a pipeline as that term is defined in Section 192.3 of the Federal\nsafety standards. However, the installation must still comply with the requirements of Section\n192.375, Service lines: plastic, and the limitations of Section 192.123, Design limitations for\nplastic pipe, are applicable.\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\\375\\74-01-25\n1\n\n<<<PAGE 2>>>\n\nSTATE OF ALABAMA\nJanuary 7, 1974\nMr. Frank Fulton, Chief Engineer\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C.\nDear Mr. Fulton:\nAs per our conversation this date on whether or not the riser put out by the Perfection\nCorporation would meet OPS's regulations, enclosed is the material that I have on this riser. I am\nalso enclosing a riser put out by Kerotest Manufacturing Company.\nWe would like your opinion at your earliest convenience as to whether either, both, or\nnone of these risers would meet OPS's regulations. Your prompt reply would be appreciated.\nYours very truly,\n\\signed\\\nLarry E. Waldrop\nUtilities Engineer\nEnclosures\ndal\\192\\375\\74-01-25\n2\n\n<<<PAGE 3>>>\n\nPOWER, WATER & GAS DEPARTMENT\nDecember 20, 1973\nMr. Larry E. Waldrop\nUtilities Engineer\nAlabama Public Service Commission\nP.O. Box 991\nMontgomery, Alabama 36102\nDear Larry:\nYou will recall some discussions that we have had recently regarding service risers and some of\nthe questions that have been raised regarding pressurized risers, plastic insertion, temperature rise,\netc. Jerald Mitchell has been interested in this subject and has had considerable discussion with us\nduring recent visits and phone conversations.\nOne item that we have all been particularly interested in is a prefabricated riser produced by\nPerfection Corporation and distributed by Mike Deason with Empire Pipe and Supply Company,\nInc. of Birmingham, Alabama.\nMike is an excellent salesman, and I think had convinced us that the Perfection riser answered all\nof our problems, including the need for cathodic protection on the riser.\nI felt that this item might indeed solve some of the problems involved with plastic services and\nunderstood from Mike that the item does meet all of the Department of Transportation\nrequirements. However, to be on perfectly safe ground, I asked that Perfection Corporation\nprovide us with evidence from DOT that this riser is approved by them.\nI enclose a copy of a letter in response to my inquiry, and my reaction to the letter is that I am\nhighly disappointed because it indicates to me no approval by DOT whatever.\nI should appreciate very much having comments from you and Jerald regarding your\ninterpretation of the content of the letter and what your reaction to the use of this item would be.\nVery truly yours,\n\\signed\\\nR.A. Azbell, General Manager\ndal\\192\\375\\74-01-25\n3\n\n<<<PAGE 4>>>\n\nPERFECTION CORPORATION\nDecember 14, 1973\nCity of Sheffield, Alabama\nPower, Water and Gas Department\nSheffield, Alabama 35660\nAttention: Mr. R.A. Azbelle\nGeneral Manager\nDear Mr. Azbelle:\nWe have been asked by our representative, Mr. Mike Deason of Empire Pipe and Supply,\nBirmingham, Alabama, to relate to you why our Perfection service line riser does not need to be\ncathodically protected.\nIt is in our estimation, the steel in this service line riser acts as no more than a protective shield for\nthe plastic contained therein, and it is not considered a part of the pipe line as that term is defined\nin Section 192.3 of the Federal safety standards. Of course, that particular portion of the service\nline riser that carries gas is above ground, and there are no D.O.T. requirements that we know of\nthat require to cathodically protect a gas carrier, be it steel or any other material, that is above\nground.\nWe hope this has answered your inquiry satisfactorily, and we thank you for your continued\ninterest in Perfection Corporation products. If there are any more questions, feel free to call us at\nany time.\nSincerely,\nPERFECTION CORPORATION\n\\signed\\\nJ. Edward Matz\nGeneral Sales Manager\ndal\\192\\375\\74-01-25\n4\n\n<<<PAGE 5>>>\n\nAttachments\ndal\\192\\375\\74-01-25","truncated":false,"body_characters":4889}