{"operation":"document","citation":"PI-78-0107","title":"Pipeline Safety Interpretation PI-78-0107","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-11-08","effective_on":null,"summary":"PI-78-0107 concerning 192.59.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0107.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0107.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0107","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/g78-11-08_Garabrant_192.59-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-78-0107\nNovember 08, 1978\nH.R. Garabrant P.E.\nGas Utilities Safety Engineer\nUtilities Division\nSouthern Arizona O\nffice 415 W. Congress Street\nTucson, Arizona 85701\nDear Mr. Garabrant:\nThis refers to your letter of August 7, 1978, to Mr. Frank Fulton suggesting that Section 192.321(d) be changed to\neliminate the Implication that thermoplastic pipe of 0.090 inch wall thickness is acceptable for use under Part 192\nregardless of pipe diameter.\nWe have reviewed Section 192.321(d) in light of your suggestion, and do find that the Section may have the implication\nyou suggest.\nThe purpose of Section 192.321(d) is to prescribe the minimum wall thickness of thermoplastic pipe that may be used\nwithout encasement. It is not intended to override, and in our opinion does not conflict with the allowable wall\nthickness for thermoplastic pipe set forth in ASTM D2513, which is incorporated by reference in Section 192.59.\nSection 192.321(d) could be stated in a better manner to make its purpose clearer. The Section will be a subject for\nreview during the course of our regulatory reform process, and it may be restated or otherwise changed as a result of\nthat process. Meanwhile, we plan to publish in the Advisory Bulletin a clarifying interpretation of Section 192.321(d).\nSincerely,\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nUnited States Government\nDepartment of Transportation\nResearch and Special Programs Administration\nDate: August 16, 1978\nSUBJECT: Interpretation of Section 192.321(d)\nFROM: Associate Director for Operations and Enforcement, DMT-10\nTO: Associate Director for Pipeline Safety Regulation, DMT-30\nBy letter of August 7, 1978 (copy attached), the Arizona Corporation Commission indicates the existence of a variance\nbetween Section 192.321 and ASTM D2513 and requests a correction of Section 192.321.\nThank you for a prompt interpretation of this regulation to facilitate a timely response to the Arizona Corporation\nCommission.\nRobert Paullin\n\n<<<PAGE 3>>>\n\nArizona Corporation Commission\n2222 West Encanto Blvd.\nPhoenix, Arizona 85009\nAugust 7, 1978\nMr. Frank Fulton\nState Programs\nOffice of Pipeline Safety Operations\nDepartment of Transportation\nWashington, D.C. 20590\nDear Frank:\nI have just noticed, after all these years, what I believe is a very serious and misleading flaw in Part 192.\nPlease refer to 192.321 (d), this paragraph would lead one to believe that, except for pipe with an outside\ndiameter of 0.875\", which can have a minimum wall thickness of .062\", that any size of plastic pipe could be used, as\nlong as it had a minimum wall thickness of 0.090\" and met the MAOP requirements.\nThis, of course, is not true if you refer to ASTM D2513-75b, Paragraph 6,2,1,2 and Table 4, you will find that\n0.090\" minimum wall thickness is only acceptable in sizes up to 1 ½ inches. Pipe in sizes greater than that have\nprogressively greater minimum wall thickness.\nI have just finished the investigation of a fatal accident, in which 2\" ABS pipe with .090 walls was involved and\none contributing factor I attribute to the high SDR ratio, although other factors were the primary cause, in my\nestimation.\nAlthough this pipe was selected before Part 192 was in effect, I believe that paragraph 92.321 (d) should be\ndeleted or changed to reference ASTM 2513. to prevent someone in the thinking that .090 is ok for all sizes.\nPlease confirm that my thinking in this matter is correct and turn this request over to the standards group for\ncorrection of Part 192,\nSincerely,\nArizona Corporation Commission\nH. R. Garabrant, P.E.\nGas Utilities Safety Engineer\nUtilities Division","truncated":false,"body_characters":3683}