{"operation":"document","citation":"PI-98-004","title":"UMAC, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-05-22","effective_on":null,"summary":"PI-98-004 response to UMAC, Inc. concerning 192.381.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1998/PI98004.pdf","body":"<<<PAGE 1>>>\n\nMay 22, 1998\nMr. John B. McGowan, Jr.\nPresident\nUMAC, Inc.\n120 South Ship Road,\nExton, PA 19341-2853\nDear Mr. McGowan::\nThis is in response to your letter of March 12, 1998, requesting an interpretation of how 49 CFR §192.381(a) applies to a\nmanufacturer's testing of each excess flow valve (EFV).\nYour letter stated that §192.381(a) requires a manufacturer to \"test each EFV to ensure that at 10 psig, each valve will ...\nupon closure, reduce gas flow ... for an EFV designed to allow pressure to equalize across the valve, to no more than 5\npercent of the manufacturer's specified closure flow rate, up to a maximum of 20 cubic feet per hour.\" UMAC has\ninterpreted the regulation as requiring a manufacturer to test each EFV capsule in its fabricated form to ensure that the\nreduced gas flow does not exceed the specified rate.\nYour letter explained that UMAC manufactures EFVs in capsule form, which are then fabricated into fittings and\npolyethylene (PE) or steel bodies. In UMAC's opinion it would be difficult to ensure the integrity of the \"O\" ring seal and\nguarantee the specified gas flow rates wit6hout testing the complete assembly once the EFV capsule has been inserted,\nparticularly in the tee outlet under field conditions.\nSection 192.381(a) requires a natural gas service line operator to only use EFVs that have been manufactured and tested in\naccordance with the specified performance standards. The regulation does not apply to a fitting or assembly that includes\nan EFV. The regulation does not require an operator to do any testing of valves that the manufacturer has tested in\naccordance with Section 192.381. The regulation does not require a manufacturer to test each valve, but only to conduct\ntesting to ensure that the valves meet performance standards.\nIf we can be of further assistance in this matter, please contact me at (202) 366-4565 or Mike Israni at (202) 366-4571.\nSincerely,\nRichard D. Huriaux\nDirector, Technology and Regulations\nOffice of Pipeline Safety\ncc: Richard E. Sanders, TSI\nOPS Regional Directors\nPage 1 of 1","truncated":false,"body_characters":2071}