{"operation":"document","citation":"PI-82-0107","title":"Pipeline Safety Interpretation PI-82-0107","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-07-28","effective_on":null,"summary":"PI-82-0107 concerning 192.199.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0107.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0107.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0107","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/g82-07-28_Johansen_192.199-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-82-0107\nJuly 28, 1982\nMr. Dale W. Johansen\nAssistant Director, Gas Department\nEngineering Section\nMissouri Public Service Commission\nP.O. Box 360\nJefferson City, Missouri 65102\nDear Mr. Johansen:\nWe apologize for the lateness of our response to your letter of April 14, 1981, asking whether §192.357(d) requires\nnonrelief type service regulators, which would release gas only upon failure to have their breather vents vented to the\noutside atmosphere.\nAs indicated by the enclosed interpretations (dated October 12, 1973, and November 1, 1976), §192.357(d) does not\napply to non-relief type service regulators because they do not release gas during operation. Nevertheless, nonrelief\ntype service regulators that have breather vents are subject to the requirements of §192.355(b)(2) and must he installed\nso that gas escaping from the vents in the event of diaphragm or other failure is released into the outside atmosphere.\nWe trust that this response will satisfy your concerns.\nSincerely,\nSIGNED\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nNovember 1, 1976\nMr. Leonard M. Coffelt\nMissouri Public Service Commission\nP.O. Box 360\nJefferson City, Missouri 65101\nDear Mr. Coffelt:\nThis responds to your letter dated September 21, 1976, asking that we review a previous interpretation dated October\n12, 1973, regarding 49 CFR 192.357(d). You ask whether that interpretation permits \"service regulators to be installed\nwithin a building without venting the diaphragm breather vent to the outside atmosphere.\"\nSection 192.357(d) reads:\n\"Each regulator that might release gas in its operation must be vented to the outside atmosphere.\"\nThe October 12, 1973, interpretation essentially provides that Section 192.357(d) does not apply to a regulator which\ndoes not release gas in its operation.\nThat interpretation was not intended to permit installation of a regulator with a diaphragm breather vent inside a\nbuilding without placing the discharge end of the vent outside the building. Sections 192.199(e) and 192.355(b)(2) are\nclear that the outlet of each regulator vent must be located outside.\nSincerely,\nOriginal Sign By\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 3>>>\n\nMissouri Public service Commission\nP.O. Box 360\nJefferson City, Missouri 65102\nApril 14, 1981\nMelvin A. Judah\nActing Associate Director\nOPSR-MTB-RSPA-DOT\n400 7th Street, S.W.\nWashington, D.C. 20590\nDear Mr. Judah:\nIt is requested that an interpretation be made on the following point of concern related to Part 192.\nQuestion: Is the phrase \"in its operation\", as contained in 192.357(d), intended to imply \"normal\" operation?\nThis interpretation is being requested to help clear up a point as to whether or not non-relief type service regulators,\nwhich would release gas only upon failure, are required to have their breather vents vented per 192.357(d).\nShould you have questions concerning this request, please feel free to contact me at 314/751-3456.\nSincerely,\nDale W. Johansen, Assistant Director\nGas Department - Engineering Section\n\n<<<PAGE 4>>>\n\nU. S. Department of Transportation\nResearch and Special Programs Administration\nMEMORANDUM\nDate: JUL - 1 1982 Reply to Attn. of: Fulton/63046\nSubject: INFORMATION: Interpretation of Section 192.357(d)\nFrom: Frank E. Fulton\nChief, Pipeline Safety Enforcement Division, DMT-13\nTo: Melvin A. Judah\nActing Associate Director for Pipeline Safety Regulation, DMT-30\nThe OOE does not concur with the attached proposed interpretation of Section 192.357(d). It is our opinion that the\ninterpretation is inconsistent with present day industry practice, original intent of the regulation, and previous\ninterpretations dated October 12, 1973, and November 1, 1976 (copies attached). (Also, note that the November 1,\n1976, interpretation was to the Missouri PSC.) Several State agencies, Region Chiefs, and gas operators were contacted\nto confirm present day practices. The opinions expressed were unanimous that all regulator vents should for safety\npurposes be vented to the outside atmosphere. Past enforcement practices have required that regulator vents be\ntreated in that manner. That practice is being complied with and it is recommended that the interpretation of November\n1, 1976, be maintained.\n#\nAttachments\n\n<<<PAGE 5>>>\n\nMissouri Public Service Commission\nP.O. Box 360\nJefferson City, Missouri 65102\nMarch 16, 1982\nMr. L. D. Santman\nDirector, Materials Transportation Bureau\nDepartment of Transportation\n400 7th street, S.W.\nWashington, D.C. 20590\nDear Mr. Santman:\nThis letter is being written pursuant to what I feel are extremely lengthy delays in receiving answers to requests for\ninterpretations of Part 192 pipeline safety standards submitted to the OPSR.\nI currently have two (2) requests for interpretations which I feel are quite overdue for reply. The first was submitted to\nthe OPSR April 14, 1981, and resubmitted through Mr. Frank Fulton November 17, 1981. The second was submitted to\nthe OPSR November 24, 1981, through Dr. Paullin. Both of these requests relate, as do nearly all of my requests, to areas\nof possible non-compliance discovered during compliance inspections. Answers to these requests are necessary before I\ncan proceed with necessary and proper compliance actions.\nWhile this letter specifically addresses the problems I have had receiving interpretations, I feel it should be pointed out\nthat other states in the Central Region have also experienced the same difficulty and in at least one case the delay has\nbeen even more extreme than my worst case sited above.\nCopies of the above-referenced requests are enclosed. I will most certainly appreciate any actions you can take to have\nthese answered in the near future as well as actions you can take to keep this problem from occurring in the future.\nShould you have questions concerning this matter, please feel free to contact me at 314/751-3456.\nSincerely,\nDale W. Johansen, Assistant Director\nGas Department - Engineering Section\n\n<<<PAGE 6>>>\n\nMEMORANDUM\nTo: Melvin Judah through Robert L. Paullin\nFrom: Dale W. Johansen\nPipeline Safety liaison Representative\nMissouri Public Service Commission\nSUBJECT: Request for interpretation of Section 3(a)(1) of The Natural Gas Pipeline Safety Act.\nDATE: November 24, 1981\nPursuant to a recent compliance inspection, Laclede Gas Company has questioned the retroactive application of Subpart\nI of Part 192. Laclede's contention is that the \"design\" of cathodic protection systems is included in the \"design\"\nstandards which Section 3(a)(1) of The Natural Gas Pipeline Safety Act prohibits from being applied to pipeline facilities\nin existence on the date the standards were adopted.\nThis position was discussed quite extensively at a recent meeting which was attended by Laclede's Chief Engineer, Ed\nOndak, and myself. There was no consensus opinion reached. Laclede has been informed, in writing, that the Missouri\nPSC Staff does not agree with their position, however, prior to any further compliance actions I feel it is necessary to\nreceive MTB's official position regarding this matter. Enclosed for your information is the most recent correspondence\nbetween Laclede and myself regarding this matter.\nI will certainly appreciate the most expeditious treatment you can offer in answering the following question:\nDo the \"design\" standards referenced in Section 3(a)(1) of The Natural Gas Pipeline Safety Act include the \"design\"\nof cathodic protection/systems as required by Subpart I of Part 192?\n\n<<<PAGE 7>>>\n\nMissouri Public Service Commission\nP.O. Box 360\nJefferson City, Missouri 65102\nNovember 17, 1981\nMr. Frank Fulton, Chief\nPipeline Safety Enforcement Division\nMTB-RSPA-DOT\n400 7th Street, S.W.\nWashington, D.C. 20590\nDear Mr. Fulton:\nPursuant to a conversation I had with Ed Ondak yesterday, please find enclosed a copy of my letter to Melvin Judah\nrequesting a code interpretation. I would certainly appreciate any help you can give me in getting this interpretation.\nIf you have any questions concerning this matter, please feel free to contact me at 314/751-3456.\nSincerely,\nDale W. Johansen, Assistant Director\nGas Department-Engirieering Section","truncated":false,"body_characters":8367}