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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-04-0104 ([Virginia State Corporation Commission] [Mr. Jim Hotinger])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Virginia State Corporation Commission

Individual Name: Mr. Jim Hotinger

Location State: VA Country: US

View the Interpretation Document

Response text:


U.S. Department of Transportation
Research and Special Programs Administration
400 Seventh St., S.W.
Washington, D.C. 20590

April 5, 2004

Mr. Jim Hotinger
Senior Utilities Engineer
Virginia State Corporation Commission P.O. Box 2118
Richmond, VA 23216

Dear Mr. Hotinger:

This is in response to your e-mail of February 10, 2004, in which you request an interpretation of the gas pipeline safety regulations at 49 CFR 192.197(a). You ask whether an external line supplying gas to a pilot controlling the operation of a regulator is a "static" or "control" line within the meaning of the section.

Section 192.197(a) states that no other pressure limiting device is required for a distribution system operating at less than 60 psig if the regulator conforms to six requirements. One of these requirements (at § 192.197(a)(6)) is that the regulator is self-contained with no external static or control lines. If there is an external static or control line, another pressure limiting device is required.

In an interpretation issued June 29, 1992, the Office of Pipeline Safety (OPS) said that "the 'static or control line' . . . is a line that runs from the regulator to the downstream side of the regulator used to communicate that pressure to the regulator." Under this interpretation, an external line connected to the regulator from the upstream side is NOT a static or control line.

However, we have reason to believe that this interpretation was in error. A static or control line is an external line from a regulator that is connected to the main or service line either upstream or downstream and is necessary for the safe functioning of the regulator. A "self-contained service regulator" as used in § 192.197(a)(6) does not require any external line(s) to function correctly or has internal overpressure protection, such as a relief or monitor. Another pressure limiting device is required if a regulator includes external static or control lines and does not have any internal overpressure protection, such as a relief or monitor.

If you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.


Richard D. Huriaux, P.E.
Manager, Regulations
Office of Pipeline Safety

Regulation Sections

Section Subject
192.197 Control of the pressure of gas delivered from high-pressure distribution systems