{"operation":"document","citation":"PI-79-018","title":"Columbia Gulf Transmission Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-06-01","effective_on":null,"summary":"PI-79-018 response to Columbia Gulf Transmission Company concerning 192.731, 192.739.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/PI79018.pdf","body":"<<<PAGE 1>>>\n\nJune 1, 1979\nMs. Kathleen O'Leary\nColumbia Gulf Transmission Company\n3805 West Alabama Avenue\nHouston, Texas 77001\nDear Ms. O'Leary:\nI am responding to your letter dated March 12, 1979, to Mr. George Orr, Office of Operations\nand Enforcement (Pipeline Safety), Houston, Texas, in which you question the applicability of 49\nCFR 192.731, 192.739, and 192.743 to relief devices or regulators installed on piping systems or\nstorage vessels not containing gas.\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 that may exist inside\ngas compressor stations. This interpretation is based on the relationship between the words\n\"pressure\" and \"gas\" occurring throughout Part 192 and in particular in the requirements of\nSection 192.195 for installation of pressure control devices. Since under Section 192.3 the term\n\"pipeline\" encompasses all the gas carrying parts of an operator's systems, the pressure relief\ndevices and limiting stations subject to Sections 192.731, 192.739, and 192.743 are those on a\n\"pipeline.\"\nWe trust this interpretation is helpful to you.\nSincerely,\n/signed/\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB/dal/192.731\n79-06-01\n1\n\n<<<PAGE 2>>>\n\nMarch 12, 1979\nMr. George Orr\nOffice of Pipeline Safety\nDepartment of Transportation\n6622 Hornwood Drive\nHouston, Texas 77074\nRe: 49 CFR §§192.731, 192.739, 192.743\nDear Mr. Orr:\nPursuant to our conversation of this afternoon, I am forwarding a copy of a letter written by\nMarshall W. Taylor, Chief of the Central Region, Office of Pipeline Safety, interpreting the above\nreferenced sections of Title 49, Code of Federal Regulations. In his letter Mr. Taylor states that\n\"the requirements of §192.731, §192.739 and §192.743 do not apply to relief devices or\nregulations which are not installed in a piping system or storage vessels containing gas . . .\"\nPresumably, the Southwest Region interprets these regulations similarly; however, inasmuch as\nColumbia Gulf operates its pipeline system primarily in the Southwest Region and not the Central\nRegion, please forward, at your earliest convenience, an opinion on the applicability of the above-\nreferenced regulations to relief devices or regulators which are installed in piping systems or\nstorage vessels not containing gas.\nThank you for your cooperation in this matter.\nSincerely,\nKathleen O'Leary\nDB/dal/192.731\n79-06-01\n2","truncated":false,"body_characters":2630}