Piedmont Natural Gas Company — Pipeline Safety Interpretation

Page 1Jan. 29, 1982 Mr. Ray B. Killough, Manager Design, Construction & Production Piedmont Natural Gas Company Post Office Box 33068 Charlotte, NC 28233 Dear Mr. Killough: We are sorry for the delay in answering your letter in which you discussed your interpretation of section 192.725(2). Our agreement with your interpretation is enclosed. If we can be of any further assistance, please call. Sincerely, Melvin A. Judah Acting Associate Director for Pipeline Safety Regulation Materials Transportation Bureau Enclosure DB C:\WP51\INTERPRT\192\725\82-01-29 1#

Page 2No. 82-1 Date; January 29,1982 DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION MATERIALS TRANSPORTATION BUREAU PIPELINE _________________________________________________________________ SAFETY REGULATORY INTERPRETATION _________________________________________________________________ NOTE:A pipeline safety regulatory interpretation applies a particular rule to a particular set of facts and circumstances, and, as such, may be relied upon only by those persons to whom the interpretation is specifically addressed. SECTION: 192.725(a) SUBJECT: Test Requirements for Reinstating Service Lines FACTS: Section 192.725(a) states, in part, that "each disconnected service line must be tested in the same manner as a new service line, before being reinstated." Question: What is the meaning of "disconnect" as used in section 192.725(a)? Interpretation: The ordinary meaning of "disconnect" is to detach or physically separate. This meaning is intended under section 192.725(a) as indicated by the notice of proposed rulemaking (Notice 70-5, 35 FR 5482) upon which the rule was based. This meaning is also consistent with the purpose of the tests. Pressure tests are required for new service lines under Subpart J to assure that potentially DB C:\WP51\INTERPRT\192\725\82-01-29 2#

Page 3hazardous leaks are discovered. Such leaks could arise during construction or repair activity required to reconnect a service line that has been physically separated. This physical separation does not necessarily occur at or near the gas main but may occur anywhere along the length of a service line. A disconnection of this type may be caused by outside forces, routine maintenance, or by compliance with the abandonment requirements of section 192.725(b). Within the industry, the word "disconnect" is sometimes used to refer to temporary discontinuance of service by closing the gas service valve. The rules proposed under Notice 70-5 above and finally adopted as sections 192.725 and 192. 727 indicate that this variation of the meaning of disconnect was not intended under either section. Therefore, a "disconnected" service line is a service line that has been physically separated from a main and does not include a service line that remains physically connected to the main, or has been taken out of service by closing a valve between the main and service line. Melvin A. Judah Acting Associate Director for Pipeline Safety Regulation Materials Transportation Bureau DB C:\WP51\INTERPRT\192\725\82-01-29 3#