{"operation":"document","citation":"PI-76-0117","title":"Pipeline Safety Interpretation PI-76-0117","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-11-29","effective_on":null,"summary":"PI-76-0117 concerning 192.123.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0117.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0117.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0117","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-11-29_Stokes_192.123%20-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-76-0117\nNovember 29, 1976\nMr. Carl J. Stokes\n27312 Eaglehelm\nCanyon Country, California 91351\nDear Mr. Stokes:\nThis responds to you letter dated October 15, 1976, and attached advertisement showing a type of meter riser\nmanufactured by R.W. Lyall and Company, Inc. You have questioned the Office of Pipeline Safety Operations (OPSO),\n“do you consider that this design of riser would meet the Federal standard and that I would be in complinace with the\ncode in using it?”\nOPSO does not endorse or certify proprietary items. It is the responsibility of the operator to assure that gas facilities\nare constructed out of materials that will maintain their structural integrity under the anticipated temperature and\nenvironmental conditions to which they are exposed and be compatible with any gas that is transported. We are\nenclosing a copy of 49 CFR Part 192 for your information and use to determine if the meter risers would meet the\napplicable standards.\nIn addition to other applicable requirements, the meter risers must meet the requirements of 49 CFR §192.375(a) for\nprotection of plastic service lines and §192.123, Design limitations for plastic pipe. With regard to the metal gas carrier,\na determination must be made as to whether or not gas is transported through it as a carrier pipe below ground. If in\nfact gas is transported through the metal gas carrier below ground, then it must comply with the requirement of Subpart\nI for corrosion control.\nThank you for your interest in pipeline safety.\nSincerely,\nOriginal signed by\nFrank E. Fulton\nCesar DeLeon\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 2>>>\n\nCarl J. Stokes\n27312 Eaglehelm\nCanyon Country, Ca 91351\nOctober 15, 1976\nMr. Jack C. Overly\nChief Western Regional Division\nOffice Pipeline Safety Operations\n831 Mitten Road\nBurlingame, Ca 94010\nDear Mr. Overly:\nI am planning on the construction of a mobile home trailer park. In designing the utility 'hook ups\" plastic pipe is to be\nused for the gas service. It is my understanding that a metal riser must come above ground from the plastic pipe and if it\nis steel must be cathodically protected according to the Federal Standard 192.455.\nAttached is an advertisement by R. W. Lyle Co. on a steel metal riser which they claim does not need cathodic\nprotection. In light of the Federal Standard I question the validity of their claim. On installation they specify that the riser\nbe installed so the point of transition of plastic to steel be at the ground surface. The claim apparently is being that there\nis no steel in the ground carrying gas and no plastic above ground carrying gas. From a practical standpoint this is an\nimpossible condition to permanently obtain since in time the soil surface level is either going to be raised or lowered by\nground planting and cultivation by the customer. It is at this transition point where the steel would be the most\nsusceptible to corrosion due to moisture, aeration of the soil and the use of fertilizers. This is also the location where gas\nleakage would be the most hazardous.\nI also understand that this type of riser is being used by the Southern California Gas Company in Los Angeles.\nMy question is - do you consider that this design of riser would meet the Federal Standard and that I would be in\ncompliance with the code in using it?\nAn answer would be appreciated as soon as possible.\nSincerely,\nCarl J. Stokes\n\n<<<PAGE 3>>>\n\nCarl J. Stokes\n27312 Eaglehelm\nCanyon Country, Ca 91351\nDecember 8, 1976\nMr. Jack C. Overly, Chief\nWestern Region\nOffice of Pipeline Safety Operations\n831 Mitten Road\nBurlingame, Ca 94010\nDear Mr. Overly:\nIn your letter to me of October 26, 1976 you wrote you had forwarded my letter concerning the R. W. Lyle riser to your\nheadquarters for an official interpretation.\nTo this date I have had no reply. I would appreciate anything you can do to expedite the matter.\nThanking you, I am\nSincerely,\nCarl J. Stokes\n\n<<<PAGE 4>>>\n\nContinental Industries, Inc.\n4102 South 74th East Avenue\nP.O. Box 994\nTulsa, Oklahoma 74101\nMr. Cesar Deleon\nActing Director,\nOffice of Pipeline Safety Operations\nWashington, D. C. 20590\nDear Mr. Deleon:\nI am enclosing a sketch of two types of meter risers we are proposing to manufacture for the gas distribution industry.\nThe thought behind this style of meter riser is to allow the gas distribution industry the option of purchasing a product\nwhich would comply with the D. O. T. Regulations prohibiting bringing thermoplastic above ground level where the\ntemperature could exceed 100° F. and still fulfill the requirements of the corrosion section of the D. O. T. Regulations.\nThe basic principle of this type of meter riser is that the junction of the plastic to metal transition inside the shield pipe is\nmade as shown in Detail \"A\" on the sketch. Above ground the metal insert becomes a gas carrying member with a plastic\nshield to above ground portion.\nOur question is (a) will a riser of this type comply with D. O. T. Regulation for limiting the thermoplastic to 100°\nwould the metal gas carrier above ground inside the thermoplastic shield require cathodic protection?\nF and (b)\nMetal insert would be made of non-ferrous metal, mild steel, or stainless steel.\nWe thank you in advance for your early reply on these questions.\nRespectfully,\nE. W. Morain, P. E.\nManager, Plastic Division","truncated":false,"body_characters":5341}