{"operation":"document","citation":"PI-76-007","title":"Tennessee Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-01-30","effective_on":null,"summary":"PI-76-007 response to Tennessee Public Service Commission concerning 192.457, 192.739.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-007","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76007.pdf","body":"<<<PAGE 1>>>\n\nJanuary 30, 1976\nMr. John Searcy\nEngineering Division\nTennessee Public Service Commission\nCordell Hull Building\nNashville, Tennessee 37219\nDear Mr. Searcy:\nThis replies to your letter of July 28, 1975, requesting interpretations for various sections of 49\nCFR 192.\nQuestion 1: Is any remedial action implied in §192.739 and\n§192.749? If so, would such action be subject to sections 192.195 thru 192.203 and 192.183 thru\n192.189, since this would involve a change after November 12, 1970?\nReply: Sections 192.739 and 192.749 govern the maintenance of pressure limiting station relief\ndevices and pressure regulating stations and vaults used in the transportation of gas. Remedial\naction as appropriate, is implicit in the requirements of these sections.\nAny specific component which is replaced, relocated, or changed as a result of inspections or tests\nmade under sections 192.739 and 192.749 must comply with all applicable requirements of 49\nCFR 192, including those to which you refer.\nQuestion 2: Does the phrase \"distribution system,\" relative to §192.741(a) and the Office of\nPipeline Safety Operations' (OPSO) interpretation presented in Advisory Bulletin 74-11, apply to\nboth high and low pressure distribution systems as defined in Part 192?\nReply: Yes.\nQuestion 3: Define \"district regulator\" as used in §192.741(a).\nReply: The term \"district regulator\" is not used in §192.741(a). we presume you are referring to\nthe term \"district pressure regulating station,\" which serves as a controlled source of gas supply to\na district, or area, within a gas distribution system.\nQuestion 4: Does §192.741(a) mean that systems which are each served individually by one\nregulator, such as distribution systems 1, 2, and 3 as identified in Diagram A, would require\ntelemetering or recording devices or that such recording devices would only be required on\ndal\\192\\739\\76-01-30\n1\n\n<<<PAGE 2>>>\n\nsystems served by more than one regulator, such as distribution system 4 identified on Diagram\nA?\nReply: Section 192.741(a) is not applicable to distribution systems served by only one district\npressure regulating station, as is the case for distribution systems 1, 2, and 3 in Diagram A.\nHowever, telemetering or recording pressure gauges may be necessary for compliance with\n§192.741(b), which applies to a distribution system supplied by a single district pressure\nregulating station. As indicated by our letter to you, dated November 6, 1974, §192.741(a) only\napplies where two or more district pressure regulating stations supply a distribution system which\nis common to all such sources of supply, such as distribution system 4 in Diagram A.\nQuestion 5: You ask us to indicate on two diagrams (A and B) where telemetering or recording\ndevices would be required. Diagram A shows three district, labeled 1, 2, and 3, each supplied by\nonly one district pressure regulating station, and two district pressure regulating stations\nsupplying a distribution system, labeled 4, which is integrally interconnected downstream from the\ntwo district pressure regulating stations. In distribution system 4, both stations are located on the\nsame side of the geometric perimeter of the distribution system.\nDiagram B has essentially the same configuration as A, except that districts 1 and 4 have been\ncombined so that the resulting integrated system is supplied by two district pressure regulating\nstations - one at a geometrically opposite extremity from the other.\nReply: In accordance with §192.741(a), telemetering or recording gauges are required for\ndistribution system 4 of Diagram A and distribution system 1/4 of Diagram B. Systems 1, 2, and\n3 of Diagram A and 2 and 3 of Diagram B are supplied by single district pressure regulating\nstations and may need telemetering or recording gauges in accordance with the criteria of\n§192.741(b).\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\739\\76-01-30\n2\n\n<<<PAGE 3>>>\n\nJuly 28, 1975\nMr. Cesar DeLeon\nDepartment of Transportation\nOffice of Pipeline Safety\n2100 2nd Street, SW\nWashington, D.C. 20590\nDear Mr. DeLeon:\n1. 2a. b. c. d. 192.739 requires inspections of pressure limiting and regulating stations, and 192.749\nrequires inspections of vaults of 200 cubic feet or more. These inspections are to\ndetermine that certain items, including capacities, pressure settings, and ventilation, are\nadequate and proper. However, if inadequate capacities or ventilation, or improper\npressure settings are found, no remedial action is specifically required except in\n192.743(c), which applies only to relief devices. Is any remedial action implied in 192.739\nand 192.749 and, if so, is it a correct interpretation that such action would be subject to\nthe requirements of 192.195 through 192.203 and 192.183 through 192.189, since this\nwould involve a change after November 12, 1970?\nRelative to 192.741(a), and the related interpretation appearing in Advisory Bulletin 74-\n11, is it a correct interpretation that the word \"distribution system\" covers both high and\nlow pressure distribution systems as defined in Part 192?\nPlease define \"district regulator\" as used in 192.741(a).\nDoes 192.741(a) mean that separate sub-systems within a common major distribution\nsystem, each served individually by one regulator, such as sub-systems 1, 2, and 3 in the\nattached diagram, would require telemetering or recording devices; or, that such separate\nsub-systems would require telemetering or recording only when served by more than one\nregulator, such as sub-system 4 in the attached diagram?\nPlease indicate on attached Diagram A where 192.741(a) would require telemetering or\nrecording devices.\ndal\\192\\739\\76-01-30\n3\n\n<<<PAGE 4>>>\n\ne. If sub-systems 1 and 4 were combined and the combination supplied by 2 regulators, one\nat each extreme of the system, as shown in Attachment B, please indicate where\n192.741(a) would require telemetering or recording devices.\nSincerely,\nJohn Searcy\nEngineering Division\nAttachments\ndal\\192\\739\\76-01-30\n4","truncated":false,"body_characters":6017}