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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-79-044 ([Virginia Corporation Commission] [Ben J. Fink])

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 Corporation Commission

Individual Name: Ben J. Fink

Location State: VA Country: US

View the Interpretation Document

Response text:

Mr. Ben J. Fink

Virginia Corporation Commission

Box 1197

Richmond, Virginia 23209

Dear Mr. Fink:

This is in reply to your letter of September 24, 1979, in which you ask if the use of a wire seal on
a closed service line valve constitutes a "locking device or other means designed to prevent the
operating of the valve by persons other than those authorized by the operator," as envisioned by
Section 192.727, Abandonment or inactivation of facilities, paragraph(d)(1), and if it does not,
what does?

A wire seal or any other type of locking device that can be removed or made ineffective by using
ordinary household tools such as a screwdriver or pliers would not prevent the opening of such a
service line valve by persons other than those authorized by the operator. Therefore, a wire seal
would not meet the requirements of Section 192.727(d)(1).

There are available several types of patented devices that would meet the requirement of Section
192.727(d)(1) that can be used with various designs of service line valves. These devices require
a special tool or key to release the valves. The tool or key would be available only to the operator
or those authorized by the operator for use in operating the valve.

We trust that this satisfactorily answers your inquiry.


Cesar DeLeon

Associate Director for

Pipeline Safety Regulation

Materials Transportation Bureau

Regulation Sections

Section Subject
192.727 Abandonment or deactivation of facilities