{"operation":"document","citation":"PI-76-075","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-12-07","effective_on":null,"summary":"PI-76-075 response to Memo: Internal concerning 192.739.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-075.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-075.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-075","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76075.pdf","body":"<<<PAGE 1>>>\n\nSPEED MEMO\nSUBJ: Interpretation of Section 192.739\nDATE: December 7, 1976\nTO: Marshall W. Taylor, II\nChief, Central Region\nINITIAL MESSAGE:\nDid the interpretation of section 192.739 set forth in my memo of October 4 to you\nprovide an adequate response to your memo of August 23?\nREPLY MESSAGE:\nThe interpretation received is an adequate response to our request of August 23; however,\nit appears that the request should have been worded differently to apply to the actual\nsituation. At the end of the first paragraph of our request, instead of stating \"Since the\nrelief device is not required by our regulations...\", it should have stated \"Since the relief\ndevice is not required by design considerations or our regulations to prevent overpressure\nof the system.\" In this case the operator has installed monitor regulators to prevent an\noverpressure situation from developing but has left the original relief devices in place.\nAs a result of our interpretation the operator will probably remove those relief valves from\nservice and will still have adequate overpressure protection as required by Part 192.\nFROM: Cesar DeLeon\nActing Director, Office of Pipeline\nSafety Operations\nDATE OF REPLY: December 14, 1976\ndal\\192\\739\\76-12-07\n1\n\n<<<PAGE 2>>>\n\nMEMORANDUM\nTO: Chief, Central Region, MTP-50-CE\nFROM: Acting Director, Office of\nPipeline Safety Operations\nDATE: October 4, 1976\nSUBJECT: Interpretation of §192.739\nYour memo of August 2, 1976, asks whether the maintenance requirements of\n§192.739 apply to pressure relief devices on a gas pipeline which are voluntarily\ninstalled by an operator at locations where relief devices are not required by\n§192.195.\nTo provide for safe operation of pipelines, the maintenance requirements of\n§§192.739 and 182.743 apply to all relief devices on a pipeline whether or not\ntheir installation is required by §192.195. This unrestricted application is indicated\nby §192.703 which provides:\n\"No person may operate a segment of pipeline, unless it maintained in accordance with this subpart.\"\nis\nIf §§192.739 and 192.743 were only intended to apply to relief devices which are\nrequired by §192.195, then the maintenance requirements would not apply to\npipelines in existence when the requirements were adopted, a result contrary to the\nintent of Congress as set forth in Sec. 3 of the Natural Gas Pipeline Safety Act of\n1968.\nCesar DeLeon\ndal\\192\\739\\76-12-07\n2","truncated":false,"body_characters":2413}