{"operation":"document","citation":"PI-77-005","title":"Panhandle Eastern Pipe Line Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-01-28","effective_on":null,"summary":"PI-77-005 response to Panhandle Eastern Pipe Line Company concerning 192.731.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77005.pdf","body":"<<<PAGE 1>>>\n\nMr. Charles H. Kent\nPanhandle Eastern Pipe Line Company\nP.O. Box 1348\nKansas City, Missouri 64141\nDear Mr. Kent:\nThis responds to your letter of November 10, 1976, in which you ask two questions regarding the\nFederal gas pipeline safety standards in 49 CFR Part 192.\nFirst, you ask whether the requirements of Sections 192.731, 192.739, and 192.743 concerning\nthe maintenance of pressure relief devices and limiting stations apply to devices and stations which\nare not part of a \"pipeline\" as that term is defined in Section 192.3. As examples, you refer to\ndevices and regulators which are used in gas compressor stations for purposes other than to\nrelieve or limit gas pressure, such as devices or regulators on compressed air or fuel systems.\nThe word \"pressure\" in Sections 192.731, 192.739, and 192.743 restricts the applicability of those\nsections to devices or stations which serve to relieve or limit gas pressure. The sections do not\napply to devices or regulators which are part of non-gas carrying equipment inside gas\ncompressor stations.\nThis interpretation is based on the relationship between the words \"pressure\" and \"gas\" occurring\nthroughout Part 192 and in particular in the requirements of Section 192.192 for installation of\npressure control devices. Since under Section 192.3 the term \"pipeline\" encompasses all the gas\ncarrying parts of an operator's systems, the pressure relief devices and limiting stations subject to\nSections 192.731, 192.739, and 192.743 are those on a pipeline.\nSecondly, you ask whether, in an acquifer storage field, gas pipelines running from the gas\ninjection system to certain water removal wells are transmission lines. Under 40 CFR 192.3, the\nterm \"transmission line\" means a pipeline other than a gathering line that ... \"transports gas within\na storage field.\" This definition is broad enough to apply to any pipeline carrying gas within the\nboundaries of a storage field. Therefore, since the lines in question are clearly not gathering lines,\nthey are classified as transmission lines under Part 192.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations\nMr. Cesar DeLeon\nDB\nC:\\WP51\\INTERPRT\\192\\731\\77-01-28\n1\n\n<<<PAGE 2>>>\n\nActing Director\nOffice of Pipeline Safety Operations\nDepartment of Transportation\nWashington, D. C. 20590\nRe: Interpretations of Part 192 Federal Pipeline Safety Regulations\nDear Mr. DeLeon:\nInterpretations are requested regarding two aspects of the regulations. First is the\napplication of Sections 192.731, 192.739 and 192.743. Do the requirements of these sections\napply to miscellaneous relief devices and regulators which are not actually part of a \"pipeline\" as\ndefined in 192.3? Examples are: relief valves and/or regulators used in compressor station\ncompressed air systems, engine cooling water and lubrication systems, pneumatic safety control\nsystems, engine fuel systems, space heating equipment fuel systems, fuel gas systems for gas\nheaters at pressure reduction stations, and fuel gas systems for heater-separators at well heads in\nstorage fields.\nThe other question regards the definition of \"transmission line\" in a storage field. In some\nacquifer storage fields certain wells are used only to remove water from the storage formation\nduring the injection season to increase the volume of the \"bubble\" available for gas. Small gas\nlines are installed from the gas injection system to these water removal wells to provide a gas lift\nfor producing the water. The produced water and gas mixture is processed through a separator\nand the residue gas returned to the suction of the storage compressors for reinjection into the\nfield. Are these lines serving the water removal wells considered to be transmission lines and\nsubject to the jurisdiction of the Office of Pipeline Safety Operations?\nYour consideration of these questions will be appreciated.\nYours truly,\nChas. H. Kent,\nSupervising Engineer\nDB\nC:\\WP51\\INTERPRT\\192\\731\\77-01-28\n2","truncated":false,"body_characters":3971}