{"operation":"document","citation":"PI-71-0114","title":"Fluor Ocean Services, Inc — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-06-23","effective_on":null,"summary":"PI-71-0114 response to Fluor Ocean Services, Inc concerning 192.179.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0114.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0114.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0114","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/g71-06-23_Lindsey_192.179-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-71-0114\nJune 23, 1971\nMr. K.B. Lindsey\nFluor Ocean Services, Inc\nEngineers Constructors\nP.O. Box 36878\nHouston, TX 77036\nDear Mr. Lindsey:\nThis is in reply to your letter of June2, 1971, concerning the application of Section 192.179 of the Federal gas pipeline\nsafety standards, to a blow-down flare system on and off-shore platform in the Gulf of Mexico.\nThe system, as you have described it, is not a pressure containing part as it is open at the end and there is no way for\npressure to be contained in the blow-down. Therefore, the blow down flare system downstream of the pressure\ncontroller does not require a pressure test.\nIt is true that §192.179 exempts offshore segments of transmission lines from having a blow-down valve. However, any\ncomponent or associated piping that is part of a pipeline as defined in §192.3 (i.e. gas moves in transportation) must be\ndesigned, constructed, tested, operated and maintained in accordance with the applicable regulations even though the\nsegment is not required by the regulations to be installed.\nIf we can be of any further assistance, please let us know.\nSincerely,\nOriginal singed by:\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nFluor Ocean Services, Inc.\nEngineers Constructors\nP.O. Box 36878 6200 Hillcroft\nHouston, Texas 77036\nJune 2, 1971\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Sixth Street, S.W.\nWashington, D.C. 20590\nAttention: Mr. Joseph C. Caldwell Acting Director\nDear Sir:\nWe have recently installed a blow-down flare system for Michigan- Wisconsin Pipe Line Company on their\njuncture platform located in Eugene Island Block 188, Offshore Louisiana. I have discussed this installation with Mr.\nJoseph de la Fuente of your Houston office, and he in turn has discussed it with Mr. Peter Kuh in Washington.\nThe flare provides a means for blowing-down the various Michigan- Wisconsin offshore pipelines that come\ntogether at this platform. The flare is isolated by manually operated valves from each of the pipelines that it serves.\nAdditionally, there is an automatically operated pressure control valve located at the inlet to the flare line to properly\nmonitor flow to the 36-inch diameter flare tip, and this controller is designed\nso that it will \"fail-closed\" in the remote event of accidental over pressuring of the flare line.\nThe question has been raised as to whether a pressure test is required of the flare line down stream of the\npressure controller. In my discussions with Mr. de la Fuente he said that his interpretation of Paragraph 192.179(c),\n(\"Each section of a transmission line, other than offshore segments, between main line valves must have a blow-down\nvalve...\") did not require\na blow-down for offshore installations, and therefore a pressure test of this blow-down system cannot be required.\nCan you please give us your interpretation of this section of the regulations. An early reply would be appreciated\nas Michigan-Wisconsin wishes to put the line in service soon.\nYours very truly,\nFLUOR OCEAN SERVICES, INC.\nK. B. Lindsby","truncated":false,"body_characters":3082}