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PHMSA Proposed Rule making for Distribution Pipelines

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1503-44

Petroleum
Jul 15, 2019
6,652
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36
ES
CFR TITLE 49 PART 192 requirements will be stiffened up for low pressure control in distribution pipelines and networks as the direct result of the Merrimack Valley fiasco. See attached.

--Einstein gave the same test to students every year. When asked why he would do something like that, "Because the answers had changed."
 
 https://files.engineering.com/getfile.aspx?folder=3bdb3738-b860-40ba-a2e0-8706fa79db9e&file=PHMSA_Nat_Gas_Distribution_NPRM_-_as_submitted_to_FR.pdf
For the slam shut device recommendation #2 on page 36, I've seen configurations with 2oo3 voting pressure transmitters / switches on the LP side acting on both of 2 shutdown devices connected in series on the HP side upstream of the worker and monitor regulators. This is for cases where the PSV on the LP side is either absent or not designed for wide open failure of the upstream regulators.
However, even this configuration would not help in cases similar to this Merrimack incident if the pressure transmitters were to be un intentionally disconnected from the LP piping during construction work.
 
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