# Memo: Internal — Pipeline Safety Interpretation

- **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:** Not available
- **summary:** PI-76-075 response to Memo: Internal concerning 192.739.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76075.pdf
**body:**

<<<PAGE 1>>>

SPEED MEMO
SUBJ: Interpretation of Section 192.739
DATE: December 7, 1976
TO: Marshall W. Taylor, II
Chief, Central Region
INITIAL MESSAGE:
Did the interpretation of section 192.739 set forth in my memo of October 4 to you
provide an adequate response to your memo of August 23?
REPLY MESSAGE:
The interpretation received is an adequate response to our request of August 23; however,
it appears that the request should have been worded differently to apply to the actual
situation. At the end of the first paragraph of our request, instead of stating "Since the
relief device is not required by our regulations...", it should have stated "Since the relief
device is not required by design considerations or our regulations to prevent overpressure
of the system." In this case the operator has installed monitor regulators to prevent an
overpressure situation from developing but has left the original relief devices in place.
As a result of our interpretation the operator will probably remove those relief valves from
service and will still have adequate overpressure protection as required by Part 192.
FROM: Cesar DeLeon
Acting Director, Office of Pipeline
Safety Operations
DATE OF REPLY: December 14, 1976
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<<<PAGE 2>>>

MEMORANDUM
TO: Chief, Central Region, MTP-50-CE
FROM: Acting Director, Office of
Pipeline Safety Operations
DATE: October 4, 1976
SUBJECT: Interpretation of §192.739
Your memo of August 2, 1976, asks whether the maintenance requirements of
§192.739 apply to pressure relief devices on a gas pipeline which are voluntarily
installed by an operator at locations where relief devices are not required by
§192.195.
To provide for safe operation of pipelines, the maintenance requirements of
§§192.739 and 182.743 apply to all relief devices on a pipeline whether or not
their installation is required by §192.195. This unrestricted application is indicated
by §192.703 which provides:
"No person may operate a segment of pipeline, unless it maintained in accordance with this subpart."
is
If §§192.739 and 192.743 were only intended to apply to relief devices which are
required by §192.195, then the maintenance requirements would not apply to
pipelines in existence when the requirements were adopted, a result contrary to the
intent of Congress as set forth in Sec. 3 of the Natural Gas Pipeline Safety Act of
1968.
Cesar DeLeon
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