{"operation":"document","citation":"PI-89-022","title":"Minnesota Office of Pipeline Safety — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1989-10-03","effective_on":null,"summary":"PI-89-022 response to Minnesota Office of Pipeline Safety concerning 192.195, 192.197, 192.199.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1989/PI89022.pdf","body":"<<<PAGE 1>>>\n\nMr. William Barbeau, Director\nMr. Ronald Wiest, Pipeline Inspector\nMinnesota Office of Pipeline Safety\nMarket House - Room 130\n289 East Fifth Street\nSt. Paul Minnesota 55101\nDear Sirs:\nThank you for you letter of August 4, 1989, requesting an interpretation of the pipeline safety\nregulations relating to service regulators and relief devices. We also appreciate the extensive\nbackup material that you included with your letter.\nIt is important to remember that the sections in question appear in Subpart D - Design of Pipeline\nComponents. The design requirements in this subpart apply to the design of a pipeline system or\ncomponent to operate under conditions that are known or reasonably foreseeable at the time of\ninstallation. The subpart is not intended to place operators under a continuing obligation to\nmonitor for variation from design conditions and to modify an original design to suit changes\nconditions, unless, of course, the operator is responsible for the changes conditions. Thus, as a\ncustomer is not bound to inform the operator about changes in end-use equipment ( e.g., a new\nstove), an operator is not bound to monitor the customer's equipment for changes and redesign its\nsystem or components to accommodate it. As you will see in the direst responses to your\nquestions that appear below, this philosophy is central to most of the issues raised in your letter.\nQ1. Definition and implication of the clause in 192.197(a)(5); connected and properly adjusted gas utilization equipment.\"\n\"unsafe operation of any\nA1. Unsafe operation of any connected and properly adjusted gas utilization equipment\nwould create an usually high likelihood that personal injury or property damage\nwould occur. For example, sufficient over pressure to create extremely high pilot\nlight flames or pressures that would extinguish pilot lights and create the possibility\nof unrestrained gas accumulation would be unsafe operation.\nQ1.A. Clarify whether or not the code requires the operator to periodically verify that all\nconnected gas utilization equipment is properly adjusted.\nA1.A. As discussed above, the design requirements do not make gas operators responsible for\nsubsequent changes that are beyond their control. This, although the operator has\nDB\nC:\\WP51\\Interprt\\192\\703\\89-10-03\n\n<<<PAGE 2>>>\n\nto meet the requirements of §192.195 in designing a customer service, the\noperator does not have to monitor the customer's equipment to verify the\ncontinuing appropriateness of the design. However, if an operator learns that its\nsystem is creating an unsafe condition, it must take appropriate action under\n§192.703(b).\nQ1.B. Clarify whether or not the code requires the operator to select a \"service regulator\" that\nwill deliver a pressure under no-flow conditions to below the rated maximum\noperating inlet pressure or below the pressure that would over pressure the\nappliance but not fail, as established by the manufacturer of the device or other\ntesting agencies based on standards such as GAMA, ANSI, or AGA.\nA1.B. Section 192.197(a) is a performance standard, meaning that it sets forth a determinable\nperformance goal, but does not specify the means by which the operator must\nachieve that goal. The goal in this case is to prevent the \"unsafe operation of any\nconnected and properly adjusted gas utilization equipment.\" This does not readily\ntranslate into establishing equipment specifications as you suggest; compliance\nmust be judged on the basis of all factors relevant to the safe operation of gas\nutilization equipment.\nQ2. Definition and implication of the clause in 192.197(b); \"unsafe over pressuring of\nthe customer's appliance if the regulator fails.\" Clarify whether or not the code\nrequires the operator to:\nEstablish this pressure within the rated maximum operating inlet pressure\nof such devices, or to a pressure below the elevated test pressure at which\nthe device would not fail as establishing by the manufacturer of the device\nor other testing agencies based on standards such as GAMA, ANSI, AGA.\nA2.A. As was the case with Question 1.B, the goal of the regulation is to ensure that the\noperator designs the service to prevent operation of the customer's equipment\nfrom significantly increasing the likelihood of personal injury or property damage.\nIn practice this is usually accomplished by choosing a service regulator that limits\nthe pressure to less than the failure pressure of the appliance regulator. Since there\nis no history of incidents resulting from over pressuring of appliances on services\nequipped with service regulators, it would appear that this is an appropriate means\nof compliance.\nQ2.B. Continuously monitor the installation of gas utilization equipment in order to know what\npressure would cause over pressuring of every specific gas utilization\nA. DB\nC:\\WP51\\Interprt\\192\\703\\89-10-03\n\n<<<PAGE 3>>>\n\nequipment/appliance. If yes, does the operator have to visit each installation on a\nperiodic basis?\nA2.B. The operator is not responsible for monitoring the equipment that the customer installs\nsubsequent to the initial installation and startup.\nQ3. A3. Interpretation of whether or not a service regulator is within code compliance\nwhen the operator says that it meets 192.197 (a) (1-6) characteristics, but has a\nrelief device. this device is usually an internal relief device that limits the\ndownstream pressure to a pressure level that could be over the maximum operating\ninlet pressure of the customer's appliance regulator, but below the elevated test\npressure that would cause the customer's appliance regulator to fail.\nClarify whether or not the addition of an internal relief valve to a service regulator\nthat meets all the requirements of 192.197 (a) (1-6) requires the operator to be\njudged under 192.197 (b).\nSection 192.197 states specifically that when a service regulator complies with the\nrequirements of §192.197 (a) (1-6) no other pressure limiting device is\nrequired. Therefore, any relief valve installed in a service regulator that otherwise\ncomplies with §192.197 is installed at the discretion of the operator. Since its\noperation neither negates not supercedes the operation of the complying service\nregulator, it is not subject to §192.197 (b). Finally, because the internal relief\nvalve is discretionary, it is not subject to the requirements of §192.199.\nI hope that this discussion has clarified for you the meaning and intent of §192.195, §192.197,\nand §192.199. If you have any further questions, please feel free to contact me.\nSincerely,\nRichard L. Beam\nDirector\n* Office of Pipeline Safety\nDB\nC:\\WP51\\Interprt\\192\\703\\89-10-03","truncated":false,"body_characters":6633}