{"operation":"document","citation":"PI-97-0103","title":"Craig Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1997-10-31","effective_on":null,"summary":"PI-97-0103 response to Craig Company concerning 192.363.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1997/g97_10_31_Craig_192.363_nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-97-0103\nU.S. Department of Transportation\nResearch and Special Programs Administration\nOctober 31, 1997\nMr. Paul V. Craig\nCraig Company\nSuite E\n4260 Bankhead Highway\nLithia Springs, GA 30057\nDear Mr. Craig:\nThis responds to your letter of June 30, 1997, requesting clarification of a letter that we sent in 1983 regarding\n§ 192.363. You note that § 192.363(b) states that \"a soft seat valve may not be used if its ability to control the\nflow of gas could be adversely affected by exposure to anticipated heat.\" You further note that a 1983\ninterpretation letter sent from this office stated that \"anticipated heat\" refers to any possible source of heat\nto which a valve may be exposed, including fire that would make the valve inoperable. The primary standard\nthat has been used to demonstrate the fire resistance of valves is 'Fire Test for Soft-Seated Ball Valves' API\n607.\"\nYour letter explains that you think that the reference to API 607 probably was used because it was the only\nstandard at the time to demonstrate the capability of a soft seated valve in a fire, but that the standard was\nwritten for valves used at a wellhead in 1,400-1,800 degrees Fahrenheit for 30 minutes. You believe that such\nanticipated heat is too high for service line valves.\nYou state that the ASME BI6 subcommittee L has discussed but not yet balloted a proposal to specify the\nminimum extreme temperature for these valves should be 400 degrees Fahrenheit for one hour. You further\nargue that the requirement for soft seats in such valves to meet the fire resistance requirements in API 607\nshould not be appropriate to demonstrate that the valve complies with § 192.363.\nOur response to the inquiry referencing the API 607 standard was only one example of an industry standard\nthat has been used to demonstrate the fire resistance of valves; and as you suggest, it may not be an\nappropriate requirement today to demonstrate that a valve complies with § 192.363. The interpretation sent\nin 1983 does not preclude having the operator determine the anticipated heat using other industry standards,\nsuch as the standard that is currently under development in the ASME B16 subcommittee L.\nI trust that this adequately responds to your question.\nSincerely,\nRichard D. Huriaux\nDirector for Technology and Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nCraig Company\n4260 Bankhead Highway, Suite E\nLuthia Springs, GA 30057\nJune 30, 1997\nMr. Caesar de Leon\nOffice of Pipeline Safety\n400 7th Street, S.W.\nWashington, DC 20590\nDear Mr. de Leon,\nI enjoyed talking with you today regarding DOT 192.363 and its interpretations, specifically, part (b) and its\nreference to soft seat valves. As I mentioned, I work for a valve manufacturer currently producing soft\nseated ball valves for this application. I also serve on ASME 8:16 subcommittee L which is in the process of\nupdating B:16.33 to include, minimum requirements for soft seated valves.\nAs you know, service line valves are typically used above ground before the service regulator and meter.\nThey enable the utility to shut-off service to the customer and also provide a means of control in the event\nof an emergency. The primary design of valves for this application has been tapered key plug valves. They\nare typically constructed of a malleable iron body with a brass key or core. Along with the metal to metal\nseal, grease is used to insure bubble tight shut-off. Because of the need for periodic maintenance and the\nindustries desire for a more reliable shut-off, ball valves have been introduced with favorable results. Ball\nvalves provide a wider operating temperature range, consistent turning torque and bubble tight shut-off in\na maintenance free package.\nQuestions have arisen regarding whether these valves meet the minimum federal safety standards as\ndefined in Pipeline Safety Standards Part 192.363. Subpart (b) states that a soft seat valve may not be used\nif its ability to control the flow of gas could be adversely affected by exposure to anticipated heat.\n\"Anticipated heat\" is further defined in 49 CFR Part 192 interpretations 83-6\nInterpretation: \"Anticipated heat\" refers to any possible source of heat to which a valve may be\nexposed, including fire that would make the valve inoperable. The primary standard that has been used\nto demonstrate the fire resistance of valves is \"Fire Test for Soft-Seated Ball Valves.\" API 607.\nThe reference to API 607 probably was used because it was the only standard available at the time to\ndemonstrate the capability of a soft seated valve in a fire. Furthermore, this standard was written for\nvalves used at the wellhead. The standard requires the valve to be enveloped in flame of 1400 - 1800\ndegrees Fahrenheit for 30 minutes. If the current, tapered key plug valve were exposed to this extreme\ncondition it would not be operable. The melting temperature range for brass is between 1550 - 1840°F.\nTherefore, all the valves currently being used in this application would not pass the extreme temperature\nrequirement of API 607. Considering the location of the valve many other problems would exist. The riser,\nservice regulator and meter would probably be melted. The gas would have to be controlled from another\npoint in the distribution system.\nASME B:16 subcommittee L has discussed the minimum extreme temperature requirement for these\nvalves. While a final decision has not been reached or balloted, 400° F for one hour is the temperature the\nmembers have discussed. Because of the many standards currently being updated by the committee it\ncould take several years to update B:16.33.\nBased on the application and location of the valve, the requirement of the valve to pass API 607 should not\nbe considered appropriate to demonstrate that the valve complies 192.363.\nI appreciate your consideration of this matter; please feel free to call if you have any questions.\nSincerely,\nPaul V. Craig","truncated":false,"body_characters":5915}