{"operation":"document","citation":"PI-75-004","title":"Office of Florida State Fire Marshal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-01-24","effective_on":null,"summary":"PI-75-004 response to Office of Florida State Fire Marshal concerning 192.503.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75004.pdf","body":"<<<PAGE 1>>>\n\nJanuary 24, 1975\nMr. Olin L. Greene, Director\nDivision of State Fire Marshal\nOffice of Florida State Fire Marshal\nLarson Building\nTallahassee, FL 32304\nDear Mr. Greene:\nThis acknowledges your letter of January 20, 1975, providing information on the use of liquefied\npetroleum gas (LPG) as a test medium.\nThe January 20 letter and your letter of November 15, 1974, requesting that we interpret 49 CFR\n192.503(b) to permit the use of LPG as a test medium, are accepted as a petition to change that\nrule.\nThis matter is assigned Docket No. Pet. 75-1. Please refer to this number in future\ncommunications on the subject.\nWe will review the petition to determine whether it warrants beginning a rule-making action. At\nthe conclusion of our review, we will notify you whether the petition for rule making is granted or\ndenied.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\503\\75-01-24\n1\n\n<<<PAGE 2>>>\n\nJanuary 20, 1975\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Caldwell:\nIn your letter of December 16, 1974, you offered your help in supporting our contention\nthat petroleum gas used as a test medium would pose no greater hazard to the public than natural\ngas. In reference thereto the following is offered for consideration in allowing liquefied petroleum\ngas to be used as a test medium for pipelines:\nSection 192.503 (b) allows:\n1. Liquid:\nThe use of liquid would be contrary to safe practices because the drying of piping\nafter testing is impractible [sic] and at best would leave some liquid residue.\n2. Natural Gas:\nNatural gas would not be available where LP gas piping is installed and even if it\nwere, natural gas contains some of the same properties found in liquefied\npetroleum gas.\n3. Inert Gas:\nInert gas would require purging the system to the atmosphere or burning; either\nwould present certain hazards that would be negated if LP gas was used. Also,\ninert gas would not be odorized, whereas LP gas would be.\nFollowing are some reasons why LP gas would offer the best test medium for\npublic safety:\n1. 2. The density of LP gas is greater than other gases and would tend to show a leak as\nopposed to gases of lesser density.\nLP gas has a more narrow range of flammability than natural gas. LP gas, 2.4% -\n9.5% gas to air. Natural gas, 5.3% - 14.0% gas to air. Therefore, offering less\nprobability of remaining in the explosive range.\ndal\\192\\503\\75-01-24\n2\n\n<<<PAGE 3>>>\n\nPage 2\n3. The technical gas safety information available to this writer suggests that any\npipeline should be tested with\nthe product to be used as the most practical way to assure leak detection.\n4. LP gas pressures are relatively low in relation to natural gas transmission systems;\ntherefore, LP gas tests would minimize the possibility of over-pressure as to\nsystem design.\nYour assistance in this matter is sincerely appreciated and if you have any\nquestions or if we can be helpful to you in any manner, please let us know.\nSincerely,\nTHOMAS D. O'MALLEY\nSTATE TREASURER\nSTATE FIRE MARSHAL\nOlin L. Greene, Director\nDivision of State Fire Marshal\ndal\\192\\503\\75-01-24\n3\n\n<<<PAGE 4>>>\n\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\n192.503(b) to permit the use of petroleum gas as a test medium.\nSection 192.503(b) prohibits the use of petroleum gas as a test medium by exclusion from the list\nof permissible media. Consequently, this section cannot be interpreted to permit the use of\npetroleum gas.\nWe would be happy, however, to treat your letter as a petition to change the rule, if you will\nprovide us further information to support your contention that petroleum gas as a test medium\nposes no greater hazard to the public than natural gas.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\503\\75-01-24\n4\n\n<<<PAGE 5>>>\n\nNovember 15, 1974\nJoseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nRequest for an Interpretation on\nTitle 49-192.503(b) _\nDear Mr. Caldwell:\nThe test medium must be a liquid, air, natural gas, or inert gas that is:\n1. 2. 3. Compatible with the materials of which the pipeline is constructed.\nRelative free of sedimentary materials\nExcept for natural gas, nonflammable.\nWe feel that when the standards were written, the use of LP Gas as a test medium was\npossibly overlooked.\nIn Florida, the State Fire Marshal's Office has permitted the use of LP Gas as a test\nmedium and has had no accidents as a result of its use.\nThe LP Gas systems are small in comparison to natural gas transmissions and distribution\nsystems and pipe size rarely exceeds two inches in diameter, therefore limiting the quantity of gas\nneeded for a test. The LP Gas companies, as a rule, do their own piping and normally do not\nhave 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\nsafety hazard than the use of natural gas. We request that an interpretation be rendered\npermitting 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\ndal\\192\\503\\75-01-24\n5\n\n<<<PAGE 6>>>\n\nOlin L. Greene, Director\nDivision of State Fire Marshal\ndal\\192\\503\\75-01-24\n6","truncated":false,"body_characters":5511}