{"operation":"document","citation":"PI-75-0113","title":"Virginia State Corporation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-11-17","effective_on":null,"summary":"PI-75-0113 response to Virginia State Corporation Commission concerning 192.187.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-0113.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-0113.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-0113","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/g75_11_17_Baumgardner_192.187_nlmxs.pdf","body":"<<<PAGE 1>>>\n\nPI-75-0113\nNovember 17, 1975\nMr. John Baumgardner\nEngineer\nVirginia State Corporation Commission\nP. O. Box 1197\nRichmond, Virginia 23209\nDear Mr. Baumgardner:\nThis responds to your letter of November 7, 1975. We agree that if a regulator located in a vault is replaced without\neffecting a change in the vault, replacement of the regulator would not make the requirements of 49 CFR 192.187\nconcerning the design of vaults apply to the vault.\nSincerely,\nSIGNED\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 2>>>\n\nCommonwealth of Virginia\nState Corporation Commission\nDivision of Public Utilities\nNovember 7, 1975\nMr. Cesar DeLeon\nActing Director\nOffice Of Pipeline Safety Operations\nDepartment of Transportation\nMaterial Trans. Bureau\n400 7th Street, SW\nWashington, D. C. 20590\nDear Mr. DeLeon:\nWe have recently had a question arise in regard to the requirement 192.187 for underground vaults.\nSpecifically this pertains to those vaults containing pressure regulating stations constructed prior to\nthe enactment of the code which have a volume in excess of 200 cubic feet. If a company upgrades a station by replacing\nthe existing regulators along with the addition of the necessary controls (say if pilot operating regulators are to replace\ndirect loading regulators) would 192.187 then apply to the vault containing the pressure regulating station?\nIt is our contention that since the code lists the requirements for pressure regulating stations and vaults\nseparately, and there has been no reconstruction or substantial change to the vault itself while upgrading the regulator\nstation, then those requirements for vaults should not apply.\nHowever, we would appreciate an interpretation on this point, and if by chance the existing vaults would be\nsubject to 192.187 under such circumstances, at what point in the replacement or regrading process would 192.187\nthen become applicable?\nWe would appreciate your reply and if there are any further questions you may have, please advise.\nYours truly,\nJohn Baumgardner\nEngineer","truncated":false,"body_characters":2065}