{"operation":"document","citation":"PI-78-0109","title":"Pipeline Safety Interpretation PI-78-0109","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-11-27","effective_on":null,"summary":"PI-78-0109 concerning 192.199.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0109.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0109.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-0109","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/g78-11-27_Sanders_192.199-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-78-0109\nNovember 27, 1978\nMr. Richard Sanders\nChief, Pipeline Safety\nMississippi Public Service Commission\nWalter Sitters State Office Building\nP.O. Box 1174\nJackson, Mississippi 39205\nDear Mr. Sanders:\nWe apologize for the delay in answering your letter of August 1, 1978, regarding Section 192.199(h).\nWith your letter, you included a sketch which shows a schematic of a regulator installation, including valves on the inlet\nand outlet of a regulator and a bypass valve. A relief valve is shown on the piping at the outlet of the regulator with\nvalve ahead of it which is marked \"locked.\"\nYou asked:\n1. \"Should an inspector cite this system under Part 192.199(h)?\"\n2. \"Should an inspector cite this system under any other portion of the code?\"\n3. \"Should an inspector accept this as meeting the law - and if he liked, recommend to the operator that\nlocking the valve would be good practice?\"\nSince Section 192.199 is in Subpart D - Design, it only applies to facilities that were readied for service after March 12,\n1971, or replaced, relocated, or otherwise changed after November 12, 1970. If the facilities illustrated by your diagram\nwere built or changed prior to these dates, Section 192.199(h) would not apply. Assuming this to be so, and the relief\nvalve does not have sufficient capacity as you illustrate, then, should the system be over pressured, Section 192.619(b)\nor Sec 192.621(b) could be applied.\nIf your diagram describes facilities built or changed after the above date(s), Section 192.199(h) would apply to the\nregulator installation. However, paragraph only applies to gas line valves installed between the system to be protected\nand Relieving or limiting device. It does not apply to valves in bypass lines because such valves do not make the relieving\nor limiting device inoperative.\nWith regard to your third question, the Materials Transportation Bureau normally does not recommend pipeline safety\npractices that are not required by the regulations.\nWe trust that this response will enable you to resolve these items of concern.\nSincerely,\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nMississippi Public Service Commission\nP.O. Box 1174\nJackson, Mississippi 39205\nAugust 1, 1978\nDear Mr. Pollen:\nA question has risen as to whether or not operators should be cited under Part 192.199 (h). Please note\nattachment \"A\" that I have prepared to enlighten you as to some of the findings our personnel have experienced\nduring inspections of operators.\nIt is my contention that the by-pass valve should be locked, since it would allow pressures to exceed the\nmaximum allowable operating pressure of the downstream distribution system. I am not sure whether or not\n192.199, Part (h), would cover or any other portion of the code covers such a situation.\nYour assistance in answering the questions that I have prepared on attachment \"A\" would be of assistance to\nour operations in the State of Mississippi.\nRespectfully yours,\nRichard Sanders\nChief, Pipeline Safety","truncated":false,"body_characters":3063}