Memo: Internal — Pipeline Safety Interpretation

Page 1September 17, 1980 Interpretation of 195.404(b) Melvin A. Judah Acting Associate Director for Pipeline Safety Regulation, DMT-30 Edward J. Onadak Chief, Central Region, DMT-14 Your memo dated May 21, 1980, requested an interpretation of section 195.404(b) concerning the required frequency of recording pipeline pressures. The attached interpretation gives the information you requested. Attachment DB C:\WP51\INTERPRT\195\404\80-09-17 1#

Page 2No. 80-14 Date: September 17, 1980 DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION MATERIALS TRANSPORTATION BUREAU _________________________________________________________________ PIPELINE SAFETY REGULATORY INTERPRETATION _________________________________________________________________No te:A pipeline safety regulatory interpretation applies a particular rule to a particular set of facts and circumstances, and, as such, may be relied upon only by those persons to whom the interpretation is specifically addressed. SECTION: 195.404(b) SUBJECT: Frequency of recorded pressures prescribed by ?195.404(b) FACTS: As given by memo dated May 21, 1980, from Chief, Central Region, DMT-14, to Associate Director for Pipeline Safety Regulation (DMT-30): ". . .an operator utilizes a system by which the pump station pressures are automatically logged on a printout every 30 minutes. . ." Questions:(1) Does this system meet the requirements of ?195.404(b)? (2) Is continuous recording of discharge pressures required by ?195.404(b)? Interpretation: The intent of the rule is to record pipeline pressures in sufficient detail to reveal the operating conditions at the time the records were made. Since pipeline pressures usually do not change rapidly, 30-minute intervals to record the pressures are adequate to meet the intent of the rule. Continuous pressure recording is not required nor is it possible in most cases. Most equipment which monitors pressures "continuously," in fact gives intermittent electrical pulses which actuate the pressure indicator. As a result, the records are not DB C:\WP51\INTERPRT\195\404\80-09-17 2#

Page 3truly continuous nor would there be any apparent advantage in having continuous pressure records. Melvin A. Judah Acting Associate Director for Pipeline Safety Regulation Materials Transportation Bureau DB C:\WP51\INTERPRT\195\404\80-09-17 3#