{"operation":"document","citation":"PI-70-0105","title":"Tennessee Gas Pipeline Co. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1970-09-29","effective_on":null,"summary":"PI-70-0105 response to Tennessee Gas Pipeline Co. concerning 192.167.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1970/g70-09-29_White_1921.67-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-70-0105\nSeptember 29, 1970\nMr. George W. White\nVice President\nTennessee Gas Pipeline Co.\nP.O. Box 2511\nHouston, Texas 77001\nDear Mr. White:\nThis is in reply to your letter concerning the application of section 192.167 (a)(4)(ii), of Title 49, Code of\nFederal Regulations.\nIt is our interpretation, that the regulation does not forbid your practice of placing one emergency shutdown\nlocation close to the portion of a compressor station most likely to be occupied, provided that there are also\ntwo places of operation that are near the exit gates in the station fence.\nThe regulations contained in Part 192 are minimum standards and are not intended in any way to limit\npractices which go beyond them in the interest of safety.\nYou may wish to raise this question at the meeting of the Technical Pipeline Safety Standards Committee\nschedules for October 29, 1970, at which the proposed agenda will include possible changes to the standards.\nThank you for your interest in pipeline standards.\nThank you for your interest in pipeline safety.\nSincerely,\nOriginal singed by;\nJoseph C. Caldwell\nDirector, Acting\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nTennessee Gas Pipeline Company\nP.O. Box 2511\nHouston, Texas 77001\nSeptember 17, 1970\nMr. Joseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\nDepartment of Transportation\n400 6th Street, SW\nWashington, D.C. 20590\nSubject: Suggested Change to Section 192.167, Subpart D, Minimum Federal Safety Standards for Gas\nPipelines.\nDear Joe:\nIt has been brought to my attention that many of the advisory provisions of 843.431 of the B31.8 Code\nconcerning compressor station emergency shut-down facilities were carried over into Section 192.67 of the\nFederal Regulations with the language changed to make these provisions mandatory. It is not appropriate that\none of these should be mandatory in the sense that it is contained in the Regulation, specifically 192.167\n(4)(ii). This provision requires that both emergency shut-down stations be located near exit gates in the station\nfence. It is our policy, and has been many years, to place one emergency shut-down location a considerable\ndistance from the compressor facilities and in the vicinity of an exit gate, but the other is placed near a\nbuilding or room that is most likely to be occupied. This will give the operator almost immediate access to the\nemergency shut-down location.\nI believe this situation can be rectified very simply by eliminating this provision from Subsection (4) and either\nnot mentioning proximity to gates at all or adding a Subsection (5) which would state that one of the\nemergency shut-down stations should be placed in the vicinity of an exit gate.\nI do not believe that this revision would necessarily require the approval of the Technical Committee.\nYours very truly,\nGeorge W. White\nVice President","truncated":false,"body_characters":2846}