Interpretation Response #PI-15-0007 ([Rhode Island Division of Public Utilities and Carriers] [Mr. Don A. Ledversis])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Rhode Island Division of Public Utilities and Carriers
Individual Name: Mr. Don A. Ledversis
Location State: RI Country: US
View the Interpretation Document
Response text:
Mr. Don A. Ledversis
Pipeline Safety Engineer
Rhode Island Division of Public Utilities & Carriers
89 Jefferson Blvd
Warwick, RI 02888
Dear Mr. Ledversis:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated September 10, 2015, you requested an interpretation of 49 CFR Part 192. Specifically, you asked whether a service line without an excess flow valve, which is damaged by excavation activity, must be replaced with an excess flow valve under the requirement of § 192.381(d).
Section 192.383(b) discusses the requirements for excess flow valve installation, as follows:
§ 192.383 Excess flow valve installation.
(b) Installation required. An excess flow valve (EFV) installation must comply with the performance standards in § 192.381. The operator must install an EFV on any new or replaced service line serving a single-family residence after February 12, 2010, unless one or more of the following conditions is present:
(1) The service line does not operate at a pressure of 10 psig or greater throughout the year;
(2) The operator has prior experience with contaminants in the gas stream that could interfere with the EFV's operation or cause loss of service to a residence;
(3) An EFV could interfere with necessary operation or maintenance activities, such as blowing liquids from the line; or
(4) An EFV meeting performance standards in §192.381 is not commercially available to the operator.
Where none of the conditions listed in § 192.383(b) are present, as discussed in your letter, a replaced service line may require the installation of an excess flow valve. A replaced service line is defined, under § 192.383(a), as "a gas service line where the fitting that connects the service line to the main is replaced or the piping connected to this fitting is replaced." Furthermore, pursuant to § 192.383(b), the installation of an excess flow valve must comply with the performance standards in § 192.381, including § 192.381(b) which states "An operator shall locate an excess flow valve as near as practical to the fitting connecting the service line to its source of gas supply."
We agree with your understanding that if an excess flow valve is installed, it should be placed as near to the source of gas supply as practical to ensure the excess flow valve protects the maximum length of service line. An excess flow valve is required if the service line from the main to the customer's house, or a segment of service line near the fitting connecting the main to the service line (where an excess flow valve is usually located), is replaced. However, an excess flow valve is not required for replacement of short segments of service line far away from the main or source of supply because excess flow valves in those locations may not provide excavation-damage protection.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
John A. Gale
Director, Office of Standards
and Rulemaking
Regulation Sections
| Section | Subject |
|---|---|
| 192.381 | Service lines: Excess flow valve performance standards |