{"operation":"document","citation":"PI-74-0151","title":"Pipeline Safety Interpretation PI-74-0151","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-12-16","effective_on":null,"summary":"PI-74-0151 concerning 192.503.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0151.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0151.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0151","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-12-12_Greene_192.503%20-lmxs.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0151\nDecember 16, 1974\nMr. Olin L. Greene, Director\nDivision of State Fire Marshal\nOffice of Treasurer\nInsurance Commissioner\nTallahassee, FL 32304\nDear Mr. Greene:\nThis responds to your letter of November 15, 1974, requesting that we interpret 49 CFR 192.503(b) to permit the use of\npetroleum gas as a test medium.\nSection 192.503(b) prohibits the use of petroleum gas as a test medium by exclusion from the list of permissible media.\nConsequently, this section cannot be interpreted to permit the use of petroleum gas.\nWe would be happy, however, to treat your letter as a petition to change the rule, if you will provide us further\ninformation to support your contention that petroleum gas as a test medium poses no greater hazard to the public than\nnatural gas.\nSincerely\nOriginal signed by:\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nOffice of Treasurer\nInsurance Commissioner\nState of Flordia\nTallahassee 32304\nNovember 15, 1974\nJoseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D. C. 20590\nRequest for an Interpretation on Title 49-192.503 (b)\nDear Mr. Caldwell:\nThe test medium must be a liquid, air, natural gas, or inert gas that is:\n1. Compatible with the materials of which the pipeline is constructed.\n2. Relative free of sedimentary materials\n3. Except for natural gas, nonflammable.\nWe feel that when the standards were written, the use of LP Gas as a test medium was possibly overlooked.\nIn Florida, the State Fire Marshal's Office has permitted the use of LP Gas as a test medium and has had no\naccidents as a result of its use.\nThe LP Gas systems are small in comparison to natural gas transmissions and distribution systems and pipe size\nrarely exceeds two inches in diameter, therefore limiting the quantity of gas needed for a test. The LP Gas companies, as\na rule, do their own piping and normally do not have access to an air compressor for pressuring the pipe.\nWe feel that the use of LP Gas as a test medium would constitute no more of a public safety hazard than the use\nof natural gas. We request that an interpretation be rendered permitting its use.\nIf we can be of assistance in any manner please let us hear from you.\nSincerely,\nTHOMAS D. O'MALLEY\nSTATE TREASURER\nSTATE FIRE MARSHAL\nOlin L. Greene, Director\nDivision of State Fire Marshal","truncated":false,"body_characters":2361}