{"operation":"document","citation":"PI-75-0110","title":"Arizona Corporation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-09-29","effective_on":null,"summary":"PI-75-0110 response to Arizona Corporation Commission concerning 192.199, 192.621, 192.743.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-0110.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-0110.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-0110","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/g75-09-29_Garabrant_192.199-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-75-0110\nSeptember 29, 1975\nMr. H. R. Garabrant\nUtilities Division\nArizona Corporation Commission\n1688 West Adams\nPhoenix, AZ 85007\nDear Mr. Garabrant:\nThis responds to your letter of June 4, 1975, which proposes a correction notice to be used as clarification and\ninformation to the public regarding the Office of Pipeline Safety Operations' (OPSO) Contract Study DOT-OS-3000S,\n“Rapid Shutdown of Failed Pipeline Systems and Limiting of Pressure to Prevent Pipeline Failure Due to Overpressure,”\nand its effect on Part 192, Sections 192.621(b) and 192.743(c).\nConclusions, opinions, or statements made in reports on contract studies performed for OPSO are those of the\ncontractor and do not necessarily state the position of OPSO. OPSO reviews and evaluates these reports and takes\naction as appropriate.\nAs you stated in your memorandum, dated May 22, 1974, to all gas operators in the State of Arizona, the grandfather\nclause is not applicable to the subject sections. A statement in your memorandum that \"…old stations that are protected\nby the grandfather clause be reviewed in light of present day standards and that these stations be replaced with up-to-\ndate stations as money and time permits …” can be considered as advisory only.\nAlso, in regard to part of paragraph four of the subject memorandum which states \"… that changing size or adding a new\nor additional relief valve (or monitor regulator) was to be classed as maintenance and not new construction, therefore\nthe station did not require entire rebuilding to new code,\" OPSO would like to call your attention to Section\n192.199(g),of the regulations which requires that overpressures-protection devices and pressure-limiting devices be\ndesigned and installed to prevent any single incident such as explosion in a vault or damage by a vehicle from affecting\nthe operation of both.. However, the intent of the subject section is separate pressure-limiting devices and\noverpressure-protection devices by distance, barrier, or separate housing, but the subject interpretation does not rule\nout other solutions that may be just as good as or better than the mentioned method of separating by distance, barrier,\nor separate housing. In other words, any new addition of pressure relief or limiting device to these existing facilities\nmust comply with the subject section of the regulation.\nI hope that this will clarify the applicability of the sections of Part 192 that apply to the correction of deficiencies of\noverpressure protection.\nSincerely,\nSIGNED\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 2>>>\n\nJune 4, 1975\nArizona Corporation Commission\n1688 West Adams\nPhoenix, Arizona 85007\nJune 4, 1975\nMr. Joseph C. Caldwell\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Seventh Street S.W.\nWashington, D.C. 20590\nDear Mr. Caldwell:\nIn regard to Report MRI-2628-TR1, Rapid Shutdown of Failed Pipeline Systems and Limiting of Pressure to Prevent\nPipeline Failure Due to Overpressure, Part I, Final Technical Report. On page 28 there is the sentence, \"Also, by virtue of\nthe 'grandfather clause' in the federal regulations, such systems are legal.\"\nI would like to point out that at first glance this might appear correct but in Part 192, Subpart L - Operation, and Subpart\nM - Maintenance, they are not grandfathered. Thus, under 192.621(b) overpressure protection is legally required on all\ndistribution pipeline systems. Also under 192.743(c), if the relieving device is of insufficient capacity, a new or additional\ndevice must be legally installed to provide additional capacity as required.\nI have convinced quite a few companies to add overprotection control in accordance with the above and have at least\nthree larger companies embarked on an upgrading program in regard to overpressure protection.\nI would like to see a correction notice issued in regard to the sentence and change the sentence to inform the public\nthat grandfathering is not applicable in this case.\nI am enclosing a copy of some correspondence in my file for your information showing how and why this office has been\ntreating this subject.\nIf I have mistakenly interpreted the operation and maintenance requirements in regard to this subject, please inform\nme. I would also be glad to discuss the economic impact of this subject with you at any time.\nSincerely,\nARIZONA CORPORATION COMMISSION\nH. R. GARABRANT, P.E.\nGas Utilities Safety Engineer\nUtilities Division","truncated":false,"body_characters":4462}