# Railroad Commission of Texas — Pipeline Safety Interpretation

**Citation:** PI-83-015  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 1983-09-08

PI-83-015 response to Railroad Commission of Texas concerning 192.181.

## Document text

<<<PAGE 1>>>

September 8, 1983
Mr. Donald R. Burleson
Chief, Eastern Region
Gas Utilities Division
Railroad Commission of Texas
Capitol Station - P.O. Drawer 12967
Austin, Texas 78711
Dear Mr. Burleson:
This responds to your letter of August 10, 1983, requesting an interpretation of 49 CFR
§192.181(b) as it relates to your safety evaluation 83-II63, 83-II64, and 83-II65 on pipeline
facilities owned and operated by Arkansas Louisiana Gas Company. We do not believe an
interpretation is necessary to answer your questions; however, we are providing the following
comments to assist you in your enforcement efforts.
Question 1: Is a distribution line valve, as described in 49 CFR 192.181(b), required on the
inlet piping to a regulator station which is located at a tap on a transmission
line? The regulator station in question was constructed after March 12,
1971, and controls the flow of gas into a distribution system.
OPSR Comment: Section 192.181(b) requires an emergency valve for each regulator station
that controls the flow or pressure of gas in a distribution system. Since the
regulator station in question controls the flow of gas in a distribution
system, a valve is required by §192.181(b).
Question 2: If a valve is required in Question #1, would sectionalizing block valves installed in
the transmission line as required by 49 CFR 192.179 satisfy the
requirement in 192.181(b) for "....a valve installed on the inlet piping...." at
a regulator station?
OPSR Comment: As long as the requirements of §192.181(b) are met, the fact that the valve
meeting those requirements is also a sectionalizing block valve does not
disqualify it under §192.181(b). There is not enough information for us to
judge whether any particular valve you may have in mind meets
§192.181(b).
dal\192\181\83-09-08
1

<<<PAGE 2>>>

2
Question 3: In a case where an interstate transmission pipeline is tapped for distribution system
gas, at what point downstream of the tap does the pipeline become subject
to state rules and enforcement? See the attached Arkansas Louisiana Gas
Company letter for other options surrounding this question.
OPSR Comment: State jurisdiction begins where the line is no longer an "interstate
transmission facility" as defined by 49 USC 1671(?). Generally, interstate
facilities are those subject to the jurisdiction of the Federal Energy
Regulatory Commission under the Natural Gas Act.
In enforcement cases where a question arises concerning jurisdiction, we suggest that the regional
offices of the Materials Transportation Bureau (Office of Operations and Enforcement) could best
determine the appropriate action on a case by case basis.
We hope that this response adequately answers your questions.
Sincerely,
Richard L. Beam
Associate Director for
Pipeline Safety Regulations
Materials Transportation Bureau
dal\192\181\83-09-08
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83015.pdf>
- Source ID: `phmsa`
- SHA-256: `bda29cf72580321355b9bc59a5fdd8b416644d82df0dd4aa652d7a9994bb6334`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T17:42:02.200Z
- Document slug: `phmsa-interpretation-pi-83-015`

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