# Arizona Corporation Commission — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-74-0112
- **title:** Arizona Corporation Commission — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1974-05-03
- **effective on:** Not available
- **summary:** PI-74-0112 response to Arizona Corporation Commission concerning 195.106.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0112.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0112.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0112
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-05-03_Garabrant_195.106-lmx.pdf
**body:**

<<<PAGE 1>>>

PI-74-0112
May 03, 1974
Mr. H. R. Garabrant
Gas Utilities Safety Engineer
Arizona Corporation Commission
1688 West Adams
Dear Mr. Garabrant:
Thank you for your letter of April 13, 1974, asking whether the class locations prescribed in 49 CFR 192 apply to a liquefied
petroleum gas (LPG) line since LPG is a compressed gas in liquid form.
The class locations in 49 CFR Part 192 were established under the Natural Gas Pipeline Safety Act of 1968 (49 USC 1671 et
seq.) for the safety regulation of pipelines used in the transportation of compressed gases in liquid form. When these
liquids, such as LPG, are transported by pipeline by a carrier engaged in interstate or foreign commerce, the transportation
is covered by the regulations in 49 CFR Part 195 promulgated under the Transportation of Explosives Act (18 USC B 31 et
seq.).
We trust this adequately responds to your inquiry.
Sincerely,
/signed/
Joseph C. Caldwell
Director
Office of Pipeline Safety

<<<PAGE 2>>>

April 13, 1974
Mr. Joseph C. Caldwell
Office of Pipeline Safety
Department of Transportation
Washington, D. C. 20550
Dear Mr. Caldwell:
Although my office is not specifically charges with approving plans of L.P.G. intra-state pipelines, I have been asked
to comment on the proposed program for the design and construction of a six inch L.P.G. pipeline, approximately four
miles long in the vicinity of Phoenix.
As proposed this line is being built to standards DOT Title 49, Part 195, subparts C, D, E and F. and liquid petroleum
transportation piping systems code AISI B 31.4-1971.
All seems to be in order, I made a few minor suggestions concerning their specifications, however, I have one
question in my mind. Part 195 does not call for class locations and since propane which is the product to be carried, in this
case is a compressed gas, we well as being in liquid form, would the class locations as called for in Part 192 be applicable?
The company involved has correctly calculated the internal design pressure at 1430 pounds, according to part 195, and it
will be the allowable working pressure of this pipeline. All fittings and the line will be hydrostatically tested to permit
operation at this pressure. However, the anticipated normal working pressure will be 1,000 PSI.
Please advise me as soon as possible regarding the applicability of the reduction of design factor F due to class
locations in regard to propane or other L.P. gasses.
Sincerely,
H. R. Garabrant
Gas Utilities Safety Engineer
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