{"operation":"document","citation":"PI-88-002","title":"Texas Gas Association — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1988-06-28","effective_on":null,"summary":"PI-88-002 response to Texas Gas Association concerning 192.739.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-88-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-88-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-88-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1988/PI88002.pdf","body":"<<<PAGE 1>>>\n\nMr. Harry E. Neel\nChairman\nTexas Gas Association\nP.O. Box 4300\nLago Vista, Texas 78645-0001\nDear Mr. Neel:\nYou have asked our opinion whether the Texas Railroad Commission is correct in its\ninterpretation that the inspection and testing requirements of §192.739 apply to a pressure\nregulator designed in accordance with §192.197 that supplies gas to a master meter system.\nFor such a regulator to be subject to §192.739, it would have to come within the meaning of\n\"pressure limiting station\" or \"pressure regulating station.\" These two terms are not defined in\nPart 192. However, they are defined in two widely accepted Industry documents, the ANSI\nB31.8 Code and the ASME Guide for Gas Transmission and Distribution Piping Systems. Under\nthese industry definitions of a \"pressure regulating station,\" it is clear that any regulator serving a\ndownstream main is a pressure regulating station. While the drafters of the industry definition\nmay not have had in mind regulators that serve mains in master meter systems, such regulators do\nmeet the terms of the definition. Also, they function similarly to other regulators that are\ngenerally recognized to come under the definition. Thus, we support the Texas Railroad\nCommission's position that §192.739 applies to pressure regulator when they are used to supply\ngas to master meter systems.\nWe will initiate a rulemaking proceeding next year to specify more clearly the situations in which\nregulators are subject to the inspection and testing requirements of §192.739. We will welcome\nyour participation in that proceeding.\nSincerely,\nRichard L. Beam\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERRPRT\\192\\739\\88-06-28\n1","truncated":false,"body_characters":1689}