Interpretation Response #PI-73-007 ([Pennsylvania Public Utility Commission] [Jerry Rich])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Pennsylvania Public Utility Commission
Individual Name: Jerry Rich
Location State: PA Country: US
View the Interpretation Document
Response text:
Mr. Jerry Rich
Director, Bureau of Investigations, Service
and Enforcement
Pennsylvania Public Utility Commission
P. O. Box 3265
Harrisburg, Pennsylvania 17120
Dear Mr. Rich:
This is in reference to your letter dated January 17, 1973, concerning a possible violation of
Section 192.199(g), 49 CFR, by the Equitable Gas Company in its regulator station R. B.-26.
The intent of Section 192.199(g) is to require gas operators to install pressure relief or pressure
limiting devices in a manner to prevent any single incident such as an explosion in a vault or
damage by a vehicle from affecting the operation of both the overpressure protective device and
the district regulator. Therefore, the overpressure protective device and the district regulator
must be sufficiently separated or adequately isolated from each other to prevent a single incident
such as an explosion or damage by a vehicle from affecting the operation of both.
Your letter indicates that the Commission believes that compliance with Section 192.199(g) was
achieved by rebuilding the regulator station according to the proposed plan in Figure 3 in the
National Transportation Safety Board Report Number NTSB-PAR-72-2. From the information
contained in the report, the regulator and the overpressure protection device were to be less than
3 feet apart in the same vault.
It appears that a single incident such as an explosion in the vault would affect the operation of
both; therefore, the proposed revamping of regulator station R.B.-26 as shown in Figure 3 of the
NTSB report would not be in compliance with Section 192.199(g).
Based on the intent of Section 192.199(g), as stated above, would you please advise whether you
believe Equitable Gas Company to be in compliance with Section 192.199(g); and, if so, in what
manner the Company has achieved compliance with this regulation.
Your immediate attention to this matter will be greatly appreciated.
Sincerely,
Joseph C. Caldwell
Director
Office of Pipeline Safety