{"operation":"document","citation":"PI-77-0105","title":"Pipeline Safety Interpretation PI-77-0105","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-04-14","effective_on":null,"summary":"PI-77-0105 concerning 192.375.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/g77-04-14_Walls_192.375-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-77-0105\nApril 14, 1977\nMr. W.L. Walls\nGas Field Service\nNational Fire Protection Association\n470 Atlantic Avenue\nBoston, MA 02210\nDear Mr. Walls:\nThis responds to your letter of February 22, 1977, regarding your comments that fire exposure of aboveground plastic\npipe should be covered in 49 CFR 192.375.\nThe requirement that the aboveground portion of a plastic service line be protected against “deterioration and external\ndamage” includes protection from fire exposure. Fire is a form of external damage and, therefore, it is not necessary\nthat it be specifically mentioned.\nI look forward to seeing you at the next TPSSC meeting on May 10, 1977.\nSincerely,\nSIGNED\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 2>>>\n\nNational Fire Protection Association\n470 Atlantic Avenue\nBoston, Massachusetts 02210\nFebruary 22, 1977\nMr. Cesar DeLeon, Acting Director\nOffice of Pipeline Safety Operations\nDepartment of Transportation\n2100 Second Street, SW\nWashington, DC 20590\nRef.: Plastic Pipelines\nDear Cesar,\nNotice 77-1, Docket No. OPSO-42 reminded me of a concern of mine. As it does not relate directly to this Notice, it\nobviously cannot be considered a response thereto. I really don't know what use can be made of my concern but, as\nleast, my conscience will be soothed.\nWhen plastic pipe was first proposed (perhaps about 10 years ago) there was pretty universal agreement that it should\nnot be permitted aboveground. There were a number of reasons for this, including its lack of resistance to heat from\nfire.\nThe National Fuel Gas Code, ANSI Z223.1 - NFPA 54, has maintained its prohibition of aboveground plastic piping since\nthe matter was initially covered in the 1969 edition, While currently undergoing extensive revision, I am unaware of any\nrequests to modify the Code in this respect,\nIn contrast, however, 49CFR 192 has permitted plastic pipe aboveground for some time. 49CFR 192,375 does require\nthat the aboveground portion of a plastic service line be protected against \"deterioration and external damage\", The\nnature of the deteriorating or damaging influences is not addressed,\nIt would seem to me that fire exposure should be one of these influences. Fires in grass, weeds, leaves, etc. are not\nuncommon in the vicinity of those risers. I would not be unduly concerned if failure from fire exposure resulted only in\nleakage aboveground. We should consider also that regulators and meters in the same fire area are also often of limited\nfire resistance. However, if the design of the casing would permit underground leakage, then I would be concerned\nsubstantially.\nHas this aspect been considered?\nSincerely,\nW.L. Walls\nGases Field Service","truncated":false,"body_characters":2703}