Interpretation Response #PI-13-0011 ([Palermo Plastics Pipe (P3) Consulting] [Dr. Gene Palermo])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Palermo Plastics Pipe (P3) Consulting
Individual Name: Dr. Gene Palermo
Location State: TN Country: US
View the Interpretation Document
Response text:
Dr. Gene Palermo
Palermo Plastics Pipe (P3) Consulting
654 Watershaw Drive
Friendsville, TN 37737
Dear Dr. Palermo:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated October 1, 2013, you requested an interpretation of a requirement of the Federal gas pipeline safety regulations at 49 CFR Part 192. Specifically, you asked whether the§ 192.281(a) restriction on the use of miter joints applies to factory-made large diameter mitered tees and elbows.
You stated that for pipe sizes 12 inches and less in diameter, gas operators generally use molded fittings; however, for pipe sizes greater than 12 inches, molded fittings are not as readily available and gas operators need to use tees and elbows that are fabricated in a factory using several miter joints. You asked if a gas operator can install a fabricated fitting (tee or elbow) containing miter joints if the fitting was made in a factory under the regulations, or whether a special permit would be required.
In reviewing the relevant code sections,§ 192.281(a) states:
(a) General. A plastic pipe joint that is joined by solvent cement, adhesive, or heat fusion may not be disturbed until it has properly set. Plastic pipe may not be joined by a threaded joint or miter joint.
However, the scope of 49 CFR Part 192, Subpart F does not apply to joining during the manufacture ofpipe or pipeline components. Section 192.271(b) states:
(b) This subpart does not apply to joining during the manufacture of pipe or pipeline components.
In order to address your question, PHMSA reviewed the reference standards applicable to plastic pipe fittings. Appendix AI ofthe American Society for Testing and Materials (ASTM) D2513-99, which is incorporated by reference in Part 192, addresses plastic pipe diameters greater than 12 inches and up to 24 inches. Section Al.4 of this appendix addresses fittings. It states that for butt-type fittings, the fittings must meet the requirements of ASTM D 3261. Section 4.1.2 of The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.
ASTM D 3261 states that fittings fabricated by thermal welding are not included in this specification.
Therefore, the referenced standard is not applicable to fabricated fittings. If an operator plans to use a fabricated fitting greater than 12 inches, the operator must first apply for a special permit under 49 CFR 190.341.1
If we can be of further assistance, please contact Tewabe Asebe of my staff at 202-366-5523.
Sincerely,
John A. Gale
Director, Office of Standards and Rulemaking
1 With regard to the September 1979 letter to Mr. Petro ofPlexco referenced in your request, it addresses the nonapplicability of§ 192.281 to manufactured fittings but does not discuss the requirements to qualify a fabricated fitting for use.
The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.
Regulation Sections
| Section | Subject |
|---|---|
| 192.281 | Plastic pipe |