{"operation":"document","citation":"PI-94-034","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-10-24","effective_on":null,"summary":"PI-94-034 response to Memo: Internal concerning 192.605.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-034.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-034.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-034","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94034.pdf","body":"<<<PAGE 1>>>\n\nMemorandum\nDate: October 24, 1994\nSubject: INFORMATION: O&M manual regulations\nFrom: Cesar De Leon, DPS-10\nTo: Richard Sanders, DTI-60\nThis responds to your memo of April 11, 1994, concerning the gas pipeline regulations in\n49 CFR § 192.605.\nRegarding § 192.605(a), you asked if it is the intent of this rule that all references to\ndesign and construction be omitted from O&M manuals. Operators must include in their\nmanuals as much design and construction information, such as welding or other joining\nprocedures, as is necessary to carry out operation, maintenance, and emergency response\nactivities. For example, if a pipeline is to be repaired by replacing a segment of pipe, the\noperator’ s O&M manual would have to have design and construction information\nappropriate for that type of repair. Also, the O&M manual must contain procedures that\nenable operating and maintenance personnel to obtain as much original design and\nconstruction information as they need to carry out their assignments. However, such\noriginal information may be maintained apart from the manual.\nRegarding § 192.605(b)(5), you suggested we remove the phrase “ plus the build-up\nallowed for operation of pressure limiting and control devices,” because it allows\noperators to exceed the MAOP during start up and shut down of a pipeline. The purpose\nof this rule is [sic] that start up and shut down of a pipeline does not cause unsafe\noverpressuring. An unsafe overpressure occurs when pressure exceeds the build-up\nallowed for operation of pressure limiting and control devices. We think the pressure\nwording of § 192.605(b)(5) is clear in this regard and should not be changed.\n#\ndal/192.605\n94-10-24","truncated":false,"body_characters":1694}