{"operation":"document","citation":"PI-83-015","title":"Railroad Commission of Texas — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-09-08","effective_on":null,"summary":"PI-83-015 response to Railroad Commission of Texas concerning 192.181.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83015.pdf","body":"<<<PAGE 1>>>\n\nSeptember 8, 1983\nMr. Donald R. Burleson\nChief, Eastern Region\nGas Utilities Division\nRailroad Commission of Texas\nCapitol Station - P.O. Drawer 12967\nAustin, Texas 78711\nDear Mr. Burleson:\nThis responds to your letter of August 10, 1983, requesting an interpretation of 49 CFR\n§192.181(b) as it relates to your safety evaluation 83-II63, 83-II64, and 83-II65 on pipeline\nfacilities owned and operated by Arkansas Louisiana Gas Company. We do not believe an\ninterpretation is necessary to answer your questions; however, we are providing the following\ncomments to assist you in your enforcement efforts.\nQuestion 1: Is a distribution line valve, as described in 49 CFR 192.181(b), required on the\ninlet piping to a regulator station which is located at a tap on a transmission\nline? The regulator station in question was constructed after March 12,\n1971, and controls the flow of gas into a distribution system.\nOPSR Comment: Section 192.181(b) requires an emergency valve for each regulator station\nthat controls the flow or pressure of gas in a distribution system. Since the\nregulator station in question controls the flow of gas in a distribution\nsystem, a valve is required by §192.181(b).\nQuestion 2: If a valve is required in Question #1, would sectionalizing block valves installed in\nthe transmission line as required by 49 CFR 192.179 satisfy the\nrequirement in 192.181(b) for \"....a valve installed on the inlet piping....\" at\na regulator station?\nOPSR Comment: As long as the requirements of §192.181(b) are met, the fact that the valve\nmeeting those requirements is also a sectionalizing block valve does not\ndisqualify it under §192.181(b). There is not enough information for us to\njudge whether any particular valve you may have in mind meets\n§192.181(b).\ndal\\192\\181\\83-09-08\n1\n\n<<<PAGE 2>>>\n\n2\nQuestion 3: In a case where an interstate transmission pipeline is tapped for distribution system\ngas, at what point downstream of the tap does the pipeline become subject\nto state rules and enforcement? See the attached Arkansas Louisiana Gas\nCompany letter for other options surrounding this question.\nOPSR Comment: State jurisdiction begins where the line is no longer an \"interstate\ntransmission facility\" as defined by 49 USC 1671(?). Generally, interstate\nfacilities are those subject to the jurisdiction of the Federal Energy\nRegulatory Commission under the Natural Gas Act.\nIn enforcement cases where a question arises concerning jurisdiction, we suggest that the regional\noffices of the Materials Transportation Bureau (Office of Operations and Enforcement) could best\ndetermine the appropriate action on a case by case basis.\nWe hope that this response adequately answers your questions.\nSincerely,\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulations\nMaterials Transportation Bureau\ndal\\192\\181\\83-09-08\n2","truncated":false,"body_characters":2856}