{"operation":"document","citation":"PI-74-014","title":"Florida Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-03-07","effective_on":null,"summary":"PI-74-014 response to Florida Public Service Commission concerning 192.281.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/PI74014.pdf","body":"<<<PAGE 1>>>\n\nMarch 7, 1974\nMr. Charles E. Batten\nDirector, Safety Department\nFlorida Public Service Commission\n700 South Adams Street\nTallahassee, FL 32304\nDear Mr. Batten:\nThis responds to your letter of February 20, 1974, asking whether a particular riser assembly\nmanufactured by Robroy Industries complies with 49 CFR 192.123(b).\nAs you noted, in a letter to Mr. Thomas G. Giles, Marker Manager, Robroy Industries, we\nindicated that the assembly casing is not a pipeline and, therefore, the requirements for corrosion\ncontrol are inapplicable to it. We added, however, that the casing's mechanical connection\nbetween the enclosed plastic pipe and a steel fitting above the ground must comply with section\n192.281(e).\nAll of the Federal safety standards applicable to plastic pipe, such as section 192.123(b), must be\nmet with respect to pipe enclosed in the casing. This does not mean that the riser assembly itself\nis governed by the same standards. Since we do not know the quality of insulation provided by\nthe casing, if any, we cannot determine whether its use would enable enclosed plastic pipe to\ncomply with section 192.123(b) in relevant situations.\nIf we may be of further assistance, please let us know.\nSincerely,\n/signed/ Cesar DeLeon\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\281\\74-03-07\n1\n\n<<<PAGE 2>>>\n\nFebruary 20, 1974\nMr. Joseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Seventh Street, S.W.\nWashington, D. C. 20590\nDear Mr. Caldwell:\nA copy of your letter to Mr. Thomas G. Giles, Market Manager of Robroy industries wherein you\nresponded to his letter of January 22, 1974 was provided to this office. Upon reviewing this letter\nand the promotional material published by Robroy Industries, it appears that they are utilizing this\nletter to show that the Office of Pipeline Safety has reviewed the product and found that it\ncomplies with applicable requirements of the Minimum Federal Safety Standards. Not knowing\nthe terms of his letter, it is difficult to determine if this was your intent or whether you answered a\nspecific question relative to the cathodic protection requirements. At any rate, the promotional\nmaterial distinctly shows the plastic pipe to extend above ground and thus it is also obvious that\nthe product must also meet the provisions of Section 192.123(b). Without proof that the\ntemperature exposure to the plastic pipe does not exceed 100° F for the thermoplastic or 150° F\nfor reinforced thermosetting plastic pipe, no plastic pipe is allowed to be brought above ground\nin the manner shown on the attached promotional material since it is still the carrier pipe.\nI ask you to review this information at the earliest possible time and advise me as to the position\nof the Office of Pipeline Safety relative to this product's compliance or noncompliance with\nSection 192.123(b). If this product complies with this Section without further experimental data\nto show compliance, then it would seem that plastic could [be, sic] brought out of ground to the\nmeter set assembly, so long as it was sleeved to prevent mechanical damage and without the need\nfor experimental data to prove that it does not exceed the temperature limitations. I am not\nadverse to approval of this riser, but that which applies to one inch of plastic above ground must\nalso apply to all plastic above ground.\nSincerely,\ndal\\192\\281\\74-03-07\n2\n\n<<<PAGE 3>>>\n\nCharles H. Batten\nDirector\nSafety Department\nNOTE:ATTACHMENT\ndal\\192\\281\\74-03-07\n3\n\n<<<PAGE 4>>>\n\nFebruary 2, 1974\nMr. Thomas G. Giles\nMarket Manager\nRobroy Industries\nRiver Road\nVerona, PA 15147\nDear Mr. Giles:\nWe have reviewed the request in your letter of January 22, 1974, for an interpretation as to\nwhether the coated flexible steel casing described in your letter requires cathodic protection.\nWe find that no cathodic protection is required for this protective flexible steel casing because the\ncasing is not considered part of a pipeline as that term is defined in Section 192.3 of the Federal\nsafety standards. However, the mechanical connection between the plastic service pipe and steel\nfitting just above the ground level must comply with Section 192.281(e) of the Federal standards.\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\\281\\74-03-07\n4\n\n<<<PAGE 5>>>\n\nJanuary 22, 1974\nMr. Joseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n400 Sixth Street SW\nRoom 107\nWashington, D. C. 20590\nDear Mr. Caldwell:\nEnclosed is information on the ROBROY RIZER-FLEX as manufactured by ROBROY\nINDUSTRIES. We are requesting an interpretation of this product meeting the OPS regulations\nas set forth in Part 192 Minimum Federal Safety Standards.\nRIZER-FLEX is a PVC plastic coated flexible steel casing that incorporates a\ncompression service adapter to make the transition at ground level from the plastic service line to\nthe conventional outside meter setting. RIZER-FLEX is designed to give protection to the plastic\nservice line brought to the ground level. The riser eliminates the need for cathodic protection and\nthe use of an underground fitting near the foundation wall. The flexible steel casing permits\ngradual bending of the plastic service pipe during installation and also compensates for ground\nmovement caused by settling or \"heaving\".\nThe casing or conduit approach to protecting the plastic service line is similar to that taken\nby others. It is our understanding that you have recently reviewed and acknowledged this\nconcept. We look forward to receiving your interpretation.\nVery truly yours,\nROBROY INDUSTRIES\nGAS PRODUCTS/COATINGS DIVISION\nThomas G. Giles\nMarket Manager\nNOTE: ATTACHMENTS\ndal\\192\\281\\74-03-07\n5","truncated":false,"body_characters":5786}