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Interpretation Response #PI-72-0118 ([Sprague Meter Company] [Mr. Howard W. Berghegger])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sprague Meter Company

Individual Name: Mr. Howard W. Berghegger

Location State: CT Country: US

View the Interpretation Document

Response text:

December 22, 1972

Mr. Howard W. Berghegger
Manager-Technical Services
Sprague Meter Company
35 South Avenue
Bridgeport, Connecticut 06601

Dear Mr. Berghegger:

This is in reply to your letter of November 17, 1972, concerning constant loaded regulators which you manufacture.  You ask for confirmation of your understanding that the inlet pressure line of such a regulator is not classed as a control line.

Section 192.197 (a) (6) of the federal regulations (49 CFR §192.197 (a) (6) states that where the maximum actual operating pressure of a distribution system is under 60 p.s.i.g., no other pressure limiting device is required if the system has a service regulator which, among other characteristics, is self-contained with no external static or control lines.  You question now, in effect, whether the inlet pressure line connecting the two valve bodies of your constant loaded regulator would be acceptable under the regulation.

Your understanding is correct.  Even though the inlet pressure line is a pilot supply line which may be necessary to the operation of the regulator, it is not classed as an external static or control line for purposes of §192.197(a)(6).

If we may be of further assists in this matter, please call on us.

Sincerely,

SIGNED
Joseph C. Caldwell
Director
Office of Pipeline Safety

Regulation Sections

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