Interpretation Response #PI-82-0100

Interpretation Response Details

State of South Carolina
The Public Service Commission
P.O. Drawer 11649
Columbia, South Carolina 29211

December 29, 1981
Mr. Melvin A. Judah
Acting Associate Director for Pipeline Safety Regulation
Material Transportation Bureau
Washington, D.C.               20590

Dear Mr. Judah:
This is in reference to your recent letter to Mr. H. R. Garabrant, Public Utility Commission of
Oregon, concerning an interpretation of Paragraph 192.727 (d). It is my understanding, in reviewing
your letter, that your office is of the opinion that stop valves need not be protected against
unauthorized operation in the event the valves are closed because of an outage. I assume your
reference to an outage could be an interruption of service involving the loss of pressure to
several customers.

If my understanding is correct, I am unable to see that your interpretation of 192.727 (d) meets
the intent of the Regulation. As stated above system outages can involve the loss of service to
several customers. In this event it would be necessary for the operator to close the stop valves to
the affected customers before service is restored to the system. Because of various circumstances,
such as the inability of the operator to gain access to relight customer appliances, the loss of
service to individual customers could involve several hours or days. Based on my experience,
because of an incident such as this, it is not uncommon for customers to open stop valves and
relight appliances. Situations such as
this can result in injuries, loss of life or property damage.

In summary we are unable to substantiate that your interpretation takes into account the above
situation and we would expect our operators to invoke the requirements of 192.727 (d) in the event
the above situation occurs.
We would appreciate your reconsideration of your interpretation of this Regulation.

Yours very truly,

James S. Stites, 
Chief Gas Department
Utilities Division

January 19, 1982

Mr. James S. Stites
Chief, Gas Department/Utilities Division
South Carolina Public Service Commission
O.O. Drawer 11649
Columbia, South Carolina 29211

Dear Mr. Stites:
Thank you for your letter of December 29, 1981, commenting on our recent interpretation of §192.727
(d).

We recognize the potential for harm when customer stop valves can be reopened by an impatient
customer following a service outage. Nevertheless, it is our opinion that the protective measures
called for by §192.727(d) were not intended to apply to temporary interruptions of gas flow that do
not involve termination of service to a customer. In making this interpretation, we were
constrained by the record of the original proceeding (docket no. OPS-10), and our reading of
that record does not lead us to conclude that §192.727(d) was intended to cover all situations in
which a customer’s stop valve is closed.

Sincerely, 

Melvin A. Judah
Acting Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau
 

Regulation Sections