Nevada Public Service Commission — Pipeline Safety Interpretation

Page 1PI-84-0104 August 31, 1984 Mr. Galen D. Denio Gas Pipeline Safety Engineer. Nevada Public Service Commission 505 East King Street Carson City, Nevada 89710 Dear Mr. Denio: This responds to your letter of August 22, 1984, concerning the application of 49 CFR Part 192, §192.739, Pressure limiting and regulating stations: Inspection and testing, and §192.743, Pressure limiting and regulating stations: Testing of relief devices, to metering and pressure regulating equipment used to deliver gas to a single commercial or industrial consumer. I am enclosing a copy of Interpretation 81-1, dated March 17, 1981. This interpretation makes it clear that these maintenance requirements (§§192.739 and 192.743) do not apply to regulator installations on service lines. Sincerely, Richard L. Beam Associate Director for Pipeline safety Regulation Materials Transportation Bureau#

Page 2No. 81-1 Date: March 17, 1981 DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION MATERIALS TRANSPORTATION BUREAU PIPELINE SAFETY REGULATORY INTERPRETATION Note: 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: §§ 192.197(c) or (c)(1), 192.739, and 192.743 SUBJECT: Pressure regulating and relief installation in high pressure distribution systems. FACTS: None QUESTION #1: Are the pressure regulating and relief installations described in §192.197(c) subject to the requirements of §192.739? ANSWER: The pressure regulating and relief installations described in §192.197 for high pressure distribution systems are those for a service line with meter and service regulator and series regulator, service regulator or other protective devices. The requirements of §192.739 are for regulating stations such as a city gate measuring and pressure regulating station or a distribution regulator station installed in a gas distribution main regulating a multiple feed distribution system. Since the pressure regulating and relief devices described in §192.197 are neither a city gate measuring and pressure regulating station nor a distribution regulating station regulating a multiple feed distribution system, they are not subject to the inspection and testing requirements of §192.739. QUESTION #2: Are the relief devices described in §192.197(c) (1) and (3) subject to the requirements of §192.743? ANSWER: For the same reasons given in the answer to question #1, the relief devices described in §192.197(c)(1) and (3) would not be subject to the testing requirements of 192.743. Melvin A. Judah Acting Associate Director for Pipeline Safety Regulation Materials Transportation Bureau#