{"operation":"document","citation":"PI-82-0100","title":"Pipeline Safety Interpretation PI-82-0100","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-01-19","effective_on":null,"summary":"PI-82-0100 concerning 192.727.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/g82-01-19_Stites_192.727-%20msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-82-0100\nJanuary 19, 1982\nMr. James S. Stites\nChief, Gas Department/Utilities Division\nSouth Carolina Public Service Commission\nO.O. Drawer 11649\nColumbia, South Carolina 29211\nDear Mr. Stites:\nThank you for your letter of December 29, 1981, commenting on our recent interpretation of §192.727 (d).\nWe recognize the potential for harm when customer stop valves can be reopened by an impatient customer following a\nservice outage. Nevertheless, it is our opinion that the protective measures called for by §192.727(d) were not intended\nto apply to temporary interruptions of gas flow that do not involve termination of service to a customer. In making this\ninterpretation, we were constrained by the record of the original proceeding (docket no. OPS-10), and our reading of\nthat record does not lead us to conclude that §192.727(d) was intended to cover all situations in which a customer’s\nstop valve is closed.\nSincerely,\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nState of South Carolina\nThe Public Service Commission\nP.O. Drawer 11649\nColumbia, South Carolina 29211\nDecember 29, 1981\nMr. Melvin A. Judah\nActing Associate Director for Pipeline Safety Regulation\nMaterial Transportation Bureau\nWashington, D.C. 20590\nDear Mr. Judah:\nThis is in reference to your recent letter to Mr. H. R. Garabrant, Public Utility Commission of Oregon, concerning\nan interpretation of Paragraph 192.727 (d). It is my understanding, in reviewing your letter, that your office is of the\nopinion that stop valves need not be protected against unauthorized operation in the event the valves are closed\nbecause of an outage. I assume your reference to an outage could be an interruption of service involving the loss of\npressure to several customers.\nIf my understanding is correct, I am unable to see that your interpretation of 192.727 (d) meets the intent of the\nRegulation. As stated above system outages can involve the loss of service to several customers. In this event it would be\nnecessary for the operator to close the stop valves to the affected customers before service is restored to the system.\nBecause of various circumstances, such as the inability of the operator to gain access to relight customer appliances, the\nloss of service to individual customers could involve several hours or days. Based on my experience, because of an\nincident such as this, it is not uncommon for customers to open stop valves and relight appliances. Situations such as\nthis can result in injuries, loss of life or property damage.\nIn summary we are unable to substantiate that your interpretation takes into account the above situation and we\nwould expect our operators to invoke the requirements of 192.727 (d) in the event the above situation occurs.\nWe would appreciate your reconsideration of your interpretation of this Regulation.\nYours very truly,\nJames S. Stites, Chief\nGas Department\nUtilities Division","truncated":false,"body_characters":2981}