{"operation":"document","citation":"PI-89-013","title":"Public Service Commission of Nevada — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1989-07-31","effective_on":null,"summary":"PI-89-013 response to Public Service Commission of Nevada concerning 192.11, 192.199, 192.739.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1989/PI89013.pdf","body":"<<<PAGE 1>>>\n\nMr. Jeffrey L. Maples\nGas Pipeline Safety Engineer\nPublic Service Commission of Nevada\nRegulatory Operations Staff\nCapitol Complex\n727 Fairview Drive\nCarson City, NV 89710\nDear Mr. Maples:\nThank you for your letter of April 20 requesting clarification of a variety of issues regarding\nliquefied petroleum gas (LPG) systems and master meter systems. We have analyzed your\nquestions and explain our conclusions below. For simplicity, we have used the same headings as\non your letter.\n49 CFR 192.11(a)\nAs we interpret the term in relation to LPG, a \"system\" normally consists of a tank storing\npetroleum, gas in liquid form, appurtenant facilities, and piping used to deliver gas to one or more\ncustomers. Separate tanks and piping serving separate sets or customers within a mobil home\npark would not constitute a single system, but separate systems.\nThe example presented in your letter, two tanks serving line customers each, with no\ninterconnection and no equipment in a public place, would be two separate systems. Neither\nwould be subject to §192.11(a) because each system serves fewer than 10 customers. Were the\ntanks or associated piping interconnected, they would constitute a single system serving 18\ncustomers and would be subject to §192.11(a). Similarly, were some part of either system located\nin a public place, that entire system would be subject to §192.11(a).\n49 CFR 192.199\nAs used in Part 192, the phrase \"district regulator station\" refers to a pressure limiting device that\nis designed and installed to limit the downstream pressure in a distribution system or part of a\ndistribution system. In an LPG system a pressure regulator on the outlet of the supply tank would\nbe enforced §192.199(g) against LPG operators. Doing so could be problematic in the absence of\na clear understanding of the meaning of \"district regulator station.\" We have scheduled a\nrulemaking proceeding to begin next March to clarify which facilities the Part 192 regulator-\nstation rules cover. We suggest that you defer decisions on compliance actions against LPG\noperators regarding §192.199(g) until the conclusion of that proceeding.\nDB\nC:\\WP51\\INTERPRT\\192\\11\\89-07-31\n1\n\n<<<PAGE 2>>>\n\nThe party who actually operates the distribution system has primary responsibility for compliance\nwith the regulations, regardless of ownership. In the examples you cited, it is possible for the\nsupplier to perform the maintenance of the tank/regulator combination under an agreement with\nthe operator, but the primary responsibility for compliance remains with the operator.\nNFPA 58 - 2213\nThe question here is whether it is acceptable, in the absence of a waiver, to set relief valves to\nstart to discharge at 275 psi rather the 250 psig as specified in NFPA (1979) Section 2213.\nAssuming the tanks in question were manufactured, designed, or installed after the 1979 edition\nof NFPA 58 was incorporated by reference in Part 192 (Amendment 192-37, 46 FR 10160,\neffective March 4, 1981), tank relief valve settings that are not in accordance with NFPA 58\n(1979) requirements would violate §192.11(a), and the system operators would be liable to\nappropriate penalties or other sanctions for the violations.\ntanks manufactured, designed, or installed before the 1979 edition was referenced would be\nsubject to the relief valve setting requirements in earlier editions of NFPA5 8 referenced in\n§192.11.\nAn operator may apply for a waiver of the NFPA setting requirement to avoid continuing\nviolations. As a certified State agency under the Natural Gas Pipeline Safety Act of 1968, the\nNevada Public Service Commission is authorized to grant waiver requests, subject to the approval\nof this office (See 40 app. U.S.C. 1672(d). We would not approve such a waiver unless there in\nan adequate explanation why the NFPA setting requirements is inappropriate to apply in a\nparticular case and why a higher setting does not reduce safety.\nI hope that the preceding discussion clarifies these issues for you. If you need any further\ninformation, please contact me.\nSincerely,\n/signed/\nRichard L. Beam\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\11\\89-07-31\n2","truncated":false,"body_characters":4161}