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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-73-007 ([Pennsylvania Public Utility Commission] [Jerry Rich])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pennsylvania Public Utility Commission

Individual Name: Jerry Rich

Location State: PA Country: US

View the Interpretation Document

Response text:

Mr. Jerry Rich

Director, Bureau of Investigations, Service
and Enforcement

Pennsylvania Public Utility Commission

P. O. Box 3265

Harrisburg, Pennsylvania 17120

Dear Mr. Rich:

This is in reference to your letter dated January 17, 1973, concerning a possible violation of
Section 192.199(g), 49 CFR, by the Equitable Gas Company in its regulator station R. B.-26.
The intent of Section 192.199(g) is to require gas operators to install pressure relief or pressure
limiting devices in a manner to prevent any single incident such as an explosion in a vault or
damage by a vehicle from affecting the operation of both the overpressure protective device and
the district regulator. Therefore, the overpressure protective device and the district regulator
must be sufficiently separated or adequately isolated from each other to prevent a single incident
such as an explosion or damage by a vehicle from affecting the operation of both.
Your letter indicates that the Commission believes that compliance with Section 192.199(g) was
achieved by rebuilding the regulator station according to the proposed plan in Figure 3 in the
National Transportation Safety Board Report Number NTSB-PAR-72-2. From the information
contained in the report, the regulator and the overpressure protection device were to be less than
3 feet apart in the same vault.

It appears that a single incident such as an explosion in the vault would affect the operation of
both; therefore, the proposed revamping of regulator station R.B.-26 as shown in Figure 3 of the
NTSB report would not be in compliance with Section 192.199(g).

Based on the intent of Section 192.199(g), as stated above, would you please advise whether you
believe Equitable Gas Company to be in compliance with Section 192.199(g); and, if so, in what
manner the Company has achieved compliance with this regulation.

Your immediate attention to this matter will be greatly appreciated.

Sincerely,

Joseph C. Caldwell

Director

Office of Pipeline Safety

Regulation Sections

Section Subject
192.199 Requirements for design of pressure relief and limiting devices