{"operation":"document","citation":"PI-74-0157","title":"San Diego Gas & Electric Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-12-27","effective_on":null,"summary":"PI-74-0157 response to San Diego Gas & Electric Company concerning 192.321.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0157.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0157.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0157","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-12-27_Hathaway_192.321-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0157\nDecember 27, 1974\nMr. Paul L. Hathaway\nVice President\nSan Diego Gas & Electric Company\nP. O. Box 1831\nSan Diego, CA 92112\nDear Mr. Hathaway:\nIn your letter of November 7, 1974, you asked for the Office of Pipeline Safety's evaluation of three types of service\nrisers being used in the San Diego area on privately owned gas systems.\nIt appears that there is a misunderstanding of the criteria for determining whether a facility is subject to the\nrequirements of Part 192. Your statement that, \"Many of these private systems are master metered or HUD financed,\nand are, therefore, subject to the Department of Transportation's Minimum Safety Standards for gas\" is not necessarily\naccurate. The applicability of 49 CFR Part 192 in these master meter systems depends upon whether or not the gas is\nstill in transportation and thus upon who is consuming the gas, the owner of the project or the individual tenants.\nUnder 49 CFR 192.3 an \"Operator\" is defined as \"a person who engages in the transportation of gas.\" The term\n\"transportation of gas\" is defined as \"the gathering, transmission, or distribution of gas by pipeline . . . “The term\n\"pipeline\" is defined as \"all parts of those physical facilities through which gas moves in transportation. . . .\nIf the owner of the piping downstream of the master meter is the consumer of the gas, as in the case of centrally located\nsystems, to provide heating, air conditioning, hot water, etc., then he is not transporting the gas and is thus not an\noperator subject to Department of Transportation (DOT) regulations. If, however, the gas is being delivered to and\nconsumed by others in the complex, then the gas is being transported and the owner of the piping downstream of the\nmaster meter does become an operator subject to DOT regulations.\nThe risers in Figures 1 and 2 appear to be of conventional design, but these sketches do not give sufficient detail to\ndetermine compliance with Part 192. Assuming that the materials in these risers meet the requirements of Part 192, the\noperator still must comply with design, construction, operation, maintenance, and corrosion control requirements.\nFigure 3 indicates a pipe diameter of 4 inches. This size would either be used as a service riser to supply a customer with\na large amount of gas or as part of a main to connect a master meter to the downstream piping. If the riser is used on a\nservice line, it would not comply with Section 192.375(a)(1), which requires that the above ground part of a plastic\nservice line he protected against deterioration and external damage. As shown in Figure 3, the PVC flange is exposed. On\nthe other hand, if the riser is used as part of a main, its installation would be prohibited by Section 192.321(a), which\nrequires that plastic pipe be installed below ground level.\nThank you for your interest in pipeline safety.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nNovember 7, 1974\nSan Diego gas & Electric Company\nP.O. Box 1831\nSan Diego, California 92112\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nWashington, D. C. 20590\nDear Mr. Caldwell:\nIn the San Diego area, PVC plastic pipe is being used in an increasing number of privately-owned (non-utility) gas\nsystems as a substitute for steel. Many of these private systems are master metered or HUD financed, and are,\ntherefore, subject to the Department of Transportation's Minimum Safety Standards for gas.\nWe are requesting a ruling concerning the acceptability of three types of risers for use on private systems\nsubject to the OPS regulations. The risers shown in Figures 1 and 2 are commonly used by private systems in the San\nDiego area. The use of design No. 3 has prompted discussion among interested parties concerning its acceptability to\nOPS.\nSome of the considerations which have been mentioned in discussing design No. 3 include:\nA. An all-plastic system will not be subject to corrosion. On a privately-owned system employing steel pipe,\ncathodic protection may not be properly installed or maintained, leading to leakage from corrosion.\nB. The required thermal and mechanical protection for above-ground plastic pipe is believed to be\nprovided by a schedule 80 PVC sleeve anchored in a concrete pad, as shown in Figure 3.\nC. Paragraph 192.375 permits a plastic \"service line\" to terminate above ground.\nD. Paragraph 192.321(a) prohibits plastic \"mains\" above ground.\nPlease advise us which of the riser designs shown in Figures 1, 2 and 3 are acceptable for use above ground to\nconnect a privately-owned line to a utility master meter as shown in Figure 4.\nYours very truly,\nPaul L. Hathaway","truncated":false,"body_characters":4686}