{"operation":"document","citation":"PI-83-0110","title":"Pipeline Safety Interpretation PI-83-0110","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-10-31","effective_on":null,"summary":"PI-83-0110 concerning 192.727.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-0110.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-0110.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-0110","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/g83-10-31_McGowan_192.727-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-83-0110\nOctober 31, 1983\nMr. John B. McGowan, Jr.\nVice President, Utilities Material and Controls\nCorporation\nP.O. Box 991\nPaoli, PA 19301\nDear Mr. McGowan:\nThis is in response to your letter of September 19, 1983, requesting our interpretation of §192.727 of 49 CFR Part 192\nrelative to the use of your company's expandable polymer plug process for permanent abandonment of a service line.\nOur position remains the same as stated in the June 2, 1981, letter of Acting Associate Director Melvin A. Judah. The\nmethod would satisfy the requirements of §192.727(d)(2) whenever service to a customer is discontinued. However,\nuse of a plug device without disconnecting the service from the source of gas would not meet the requirements of\n§192.727(b). We point out, also, that the industry Code ANSI/ASME B31.8 - 1982 and the ASME Guide for Gas\nTransmission and Distribution Piping Systems - 1983 both state that abandoned lines should be \"physically\ndisconnected\" or \"disconnected\" from all sources of gas as the first item listed under \"abandonment\" or \"abandoning\"\nrelative to this matter.\nAs we stated in our letter of July 15, 1981, if you or gas opera-\ntors wish to request a rule change to permit use of the process for abandonment of gas services, the guidelines in 49\nCFR §106.31 would be applicable.\nI trust this information will be of assistance to you.\nSincerely,\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nSeptember 19, 1983\nMr. Melvin A. Judah\nChief, Technical Division\nOPSR/MTB\nResearch & Special Programs Administration\nDepartment of Transportation\nWashington, DC 20590\nDear Mel:\nThank you so much for your time and that of your staff on Friday, September 2, 1983. The meeting was most\ninformative and produc-\ntive.\nAs you know, our company is currently developing a process whereby a heat expandable polymer plug will be inserted\nin a service line, positioned at the second threaded joint of the tee and expanded to permanently shut off gas flow on\nlow pressure services. The pipe would then be internally cut three feet from the basement wall of the dwelling, the\nstub removed and the wall patched.\nOur interpretation of 192.727 is that such a system satisfies the requirements for a permanent abandonment of a\nservice line. You will recall some confusion about what this section provides for service abandonments - it seems to be\nambiguous.\nPlease consider this a formal request for your departments interpretation of this section as it applies to our system for\npermanent abandonments. Enclosed for your perusal are two of my earlier correspondences with your department\nconcerning this matter.\nI anxiously await your response.\nSincerely,\nJohn B. McGowan, Jr.\nVice President\nEnclosure\n\n<<<PAGE 3>>>\n\nDecember 30, 1980\nMr. Paul J. Cory\nMaterial Transportation Bureau\nOffice of Pipeline Safety Operations\nU.S. Department of Transportation\n400 Seventh Street, SW\nWashington, D.C. 20590\nDear Paul:\nThis letter follows-up our recent telephone conversation concerning accepted and approved methods of permanently\nabandoning or deactivating the service lines to customers of pubic gas distribution utilities. -More specifically: Section\n192.727-\"Abandonment or inactivation of facilities\" of the Federal Code.\nOur company is currently interested in marketing an internal, heat expandable polymer plug, which would be inserted\nfrom the dwelling end of the service, out and expanded into the tee connection at the main. This process would\neliminate excavation, which is today one of the greatest costs in a utility maintenance budge.\nIt is our interpretation that this method would be acceptable under Section (d), Part (2) of 192.727. A number of our\nclients interpret the code to read that a physical disconnection, i.e.; cutting the service away from the main, is required.\nAs I interpret this section, a physical disconnect is only one of the options which can be followed.\nIt would be helpful if you could send a written clarification on this question. Please include whether physical\ndisconnection of the service line from the main supply is optional or manditory [sic].\nIf you have any questions regarding our systems, please do not hesitate to contact our office.\nThanking you for your attention to this request, I am,\nSincerely,\nJohn B. McGowan\nPresident\nEnclosure\n\n<<<PAGE 4>>>\n\nJune 2, 1981\nMr. John B. McGowan\nPresident, Utilities Material\n& Controls Corporation\nP.O. Box 991\nPaoli, Pennsylvania 19301\nDear Mr. McGowan:\nThis responds to your recent question regarding 49 CFR §192.727(d)(2).\nThe method you describe to prevent the flow of gas by the inser-\ntion of an expandable plastic device into a service line would satisfy the requirements of §192.727(d)(2). This device\nmay be used whenever service to a customer is discontinued.\nThe first paragraph of your letter mentions permanently abandon-\ning a service line. To avoid any misunderstanding about the application of the various paragraphs of §192.727,\nparagraph (b) deals with all pipelines which have been abandoned, and specifi-\ncally requires a physical disconnect. The use of a plug device without a physical disconnect would not satisfy the\nrequirements of §192.727(b).\nSincerely,\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 5>>>\n\nJune 5, 1981\nMr. Melvin A. Judah\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Judah:\nRegarding the receipt of your letter dated June 2, 1981, in reference to the interpretation of 49 CFR §192.727(d)(2).\nAs you know, we have developed a new system for the abandonment and/or the disconnection of gas service lines\nwithout excavation at the main which, of course, is a major cost to the consumer and the utilities, as well as the general\nnuisance to the general public. In addition to the general plugging system we have a method to physically disconnect\nservice lines by internally cutting the service, thus rendering it completely separated from the main.\nMr. Robert Langley, of your office, and myself had a lengthy phone conversation in regard to the paragraph\n§192.727(b), as to where the service line had to be disconnected.\nWe would very much like to invite you and your people involved in this area to visit our Frazer, Pennsylvania (suburban\nPhiladel-\nof how it works.\nphia) laboratory, where we could demonstrate our present system so that your people could get first hand knowledge\nWe feel that our system, which is a new state of art, could be considered for a rule change if the need exists.\nWe thank you for your letter and hope that you will accept our invitation to visit our facilities.\nBest Regards,\nJohn B. McGowan\nPresident\n\n<<<PAGE 6>>>\n\nJuly 15, 1981\nMr. John B. McGowan\nPresident, Utilities Material and Controls\nCorporation\nP.O. Box 991\nPaoli, PA 19301\nDear Mr. McGowan:\nThis responds to your letter of June 5, 1981, about your system for \"abandonment and/or the disconnection of gas\nservice lines\" and your kind invitation to our staff to visit your laboratory in Frazer, Pennsylvania.\nI am sure that we would find the demonstration of your new system most interesting. Regrettably, because of recent\nstaff deple-\ntions and high workload priorities, we will not be able to accept your offer.\nIf you or the gas operators you supply wish to request a rule change to permit a system as you have described to be\nused for the abandonment of gas services, we list the following guidelines for proposing rule changes. Of particular\nimportance are the technical facts supporting any change proposed for the safety regulations.\nMTB's rulemaking procedures in 49 CFR §106.31, Petitions for rulemaking, state:\n(a) Any interested person may petition the Director to establish, amend, or repeal a regulation.\n(b) Each petition filed under this section must-\n(1) Set forth the tests or substance of the regulation or amendment proposed, or specify the rule that the\npetitioner seeks to have repealed, as the case may be;\n(2) Explain the interest of the petitioner in the action requested; and\n(3) Contain any information and arguments available to the petitioner to support the action sought.\nBy way of advice, the \"information and arguments\" of (b)(3) above should cover the following points:\n What is the safety problem relating to the action sought?\n Why is the existing rule, or lack of rule, inadequate? Include history or origin of existing safety situation\nwith facts supporting need for change.\n How will the proposed action solve the problem? Why is it the best of alternative solutions to the\nproblem in terms of costs, feasibility, etc.\n State any anticipated benefits (quantify if possible).\n What is the estimated cost, or the savings, of the proposal?\nI trust the above information will be of assistance to you.\nSincerely,\nMelvin A. Judah\n\n<<<PAGE 7>>>\n\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 8>>>\n\nNovember 2, 1983\nMr. Richard L. Beam, Associate Director\nOffice of Pipeline Safety Regulations\nMaterial Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Beam:\nI recently received a copy of your memorandum dated September 14, 1983, to Robert L. Paullin regarding a\nrequest for clarification of Section 192.614(b)(4). I was shocked to learn that this memorandum completely\ncontradicted a position your office took on this matter in June, 1983. This turnaround concerns me greatly because the\ncredibility of the Office of\nPipeline Safety Regulation has been seriously questioned by myself and many of my state pipeline safety colleagues. I\nwould expect that any verbal communication of positions would carry the same weight or importance as any written\nposition.\nBeing a strong supporter of the Federal/State partnership in pipeline safety, I believe we must all work together\nto accomplish the task of fulfilling our responsibilities under the appropriate Federal and State pipeline safety laws. I\nwould encourage your office to establish procedures to inform interested persons of actions your office intends to take\nregarding inquiries from those interested people prior to circulating such material throughout the country. This should\nhelp ensure that the issue being addressed was completely understood.\nI do not believe my June 17, 1983, letter to Mr. Edward Ondak regarding Section 192.614(b)(4) was properly\ncharacterized or addressed in your September 14, 1983, answer to Mr. Paullin's\nrequest for clarification. I am willing to discuss this matter with you or your staff and if additional information or further\nclarification is required, I will be pleased to work with you.\nI would appreciate your consideration in the matter and will indicate that we are not attempting to weaken the\nintent of the regulations but are recognizing that damage prevention programs are different from state to state. The\nMichigan damage preven-\ntion legislation (1974 PA 53) and the one call communication system (MISS DIG) is the heart of the damage prevention\nprogram in Michigan. This program, together with the cooperation of excavators and various utilities, has operated in\nan effective and efficient manner and it is my desire to see that continue.\nVery truly yours,\nMichael J. Kidd, Supervisor\nOffice of Gas Operations","truncated":false,"body_characters":11411}