{"operation":"document","citation":"PI-04-0101","title":"Dominion Transmission, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-01-22","effective_on":null,"summary":"PI-04-0101 response to Dominion Transmission, Inc. concerning 192.701.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-04-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2004/g04-01-22_Schwoeble_192.701-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-04-0101\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nWashington, D.C 20590\nJanuary 22, 2004\nMr. Martin C. Schwoeble\nPipeline Integrity Compliance Specialist\nDominion Transmission, Inc.\n445 West Main Street\nClarksburg, WV 26301\nDear Mr. Schwoeble:\nThis is in response to your letter of November 3, 2003, in which you request an interpretation of the Federal gas pipeline\nsafety regulation at 49 CFR 192.739, Pressure Limiting and Regulating Stations: Inspections and Testing. The question\narises from small regulators on the Dominion Transmission, Inc. (DTI) system that provides protection for operating, or\nend-use, equipment. These types of regulators are installed by the manufacturer of the equipment and are not intended\nto be inspectible by pipeline operators.\nSection 192.701, Scope, notes the Subpart M \"prescribes minimum requirements for maintenance of pipeline facilities.\"\nSection 192.739 must be read in cognizance of this scope statement. It is clear that § 192.739 is intended to address\ninspection and testing of pressure limiting and regulating stations that are necessary to maintain safe pressures on the\npipeline facility, not on end-use equipment.\nThis is consistent with the June 28, 1988, interpretation letter cited in your letter. In that interpretation, we note that a\nregulator subject to § 192.739 would have to fall within the definition of \"pressure limiting station\" or \"pressure\nregulatory station\" as these terms are defined in the ASME B31.8 standard. Under these definitions, it is clear that any\nregulator serving a downstream piping is a pressure regulating station and is subject to inspection and testing in\naccordance with § 192.739. Conversely, a regulator that is NOT intended to protect a downstream piping, but rather\nserves only to protect end-use equipment, such as a compressor, would not be subject to § 192.739.\nIf you have any further questions about the pipeline safety regulations, please contact me at (202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nDominion Transmission inc.\n445 West main Street\nClarksburg, WV 26301\nRichard D. Huriaux\nDepartment Of Transportation, Office Of Pipeline Safety\n400 7th Street\nSouthwest, Room 7128\nWashington D.C., 20590\nNovember 3, 2003\nRE: Interpretation Request\nDear Mr. Huriaux,\nThis letter's purpose is to ask for an interpretation of CFR Part 192.739, \"Pressure Limiting and Regulating Stations:\nInspections and Testing\" for Dominion Transmission Incorporated (DTI).\nDTI is currently inspecting numerous small regulators downstream of the first initial regulators (first or second main\npressure cut) on fuel gas lines that feed various types of equipment such as main compressor units, pipeline heaters and\ndehydration systems, etc. Typically, these types of fuel regulators consist of 1\" or smaller. They are not intended to\nprotect a transmission pipelines maximum operating pressure. Their sole purpose is to provide protection for the\noperating equipment. These types of small regulators are usually installed by the manufacturer of the equipment and\nwould require major piping changes to conduct an inspection of them.\nPart 192.739 states that \"Each pressure limiting station, relief device (except rupture discs), and pressure regulating\nstation and its equipment must be subjected...\" to inspection annually, not to exceed 15 months. What is the proper\ndefinition of a pressure limiting or regulating \"station\"? An interpretation found in WinDOT, dated 06/28/88, states that\na pressure regulating station is any regulator serving a downstream \"main\". This is not the case regarding the\naforementioned equipment examples.\nIt is DTI's stance that the jurisdictional transition point should be the first valve downstream of the last regulator and/or\nrelief valve associated with the first pressure cut from the transmission pipeline, including any regulator within the by-\npass. If a measurement device used for consumption exists beyond this point, then the measurement device becomes\nthe jurisdictional transition point. All downstream pressure limiting and regulating devices from this jurisdictional\ntransition point would then be exempt from Part 192.739.\nDTI has a vast amount of these types of small fuel line regulators throughout our operating system and the inspection of\nthem is a burdensome task that is costly and has been found to be of no benefit. DTI thereby requests that the Office of\nPipeline Safety please grant these types of small fuel regulators be exempt from Part 192.739.\nWe appreciate any input you may have regarding this matter. If you have any questions, please feel free to contact me\nvia the following phone numbers:\nOffice: (724) 468-7726\nCell Phone: (724) 433-4038\nRespectfully,\nMartin C. Schwoeble\nDTI Pipeline Integrity Compliance Specialist","truncated":false,"body_characters":4914}