{"operation":"document","citation":"PI-99-0100","title":"California Public Utilities Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-02-08","effective_on":null,"summary":"PI-99-0100 response to California Public Utilities Commission concerning 192.731, 192.739, 192.743.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1999/g99_02_08_Jhala_192.731_msfX.pdf","body":"<<<PAGE 1>>>\n\nPI-99-0100\nU.S. Department of Transportation\nMr. Mahendra Jhala\nChief, Utilities Safety Branch\nConsumer Services Division\nCalifornia Public Utilities Commission\n505 Van Ness Avenue, 2nd Floor\nSan Francisco, CA 94102\nDear Mr. Jhala:\nThis responds to your request for an official interpretation of 49 CFR 192.731, 192.739, and 192.743. You\nasked if these sections apply to compressor station relief devices that relieve natural gas in equipment and\nsystems associated with operation of the compressor, such as fuel gas lines and instrument gas lines.\nWe previously said that these sections apply to all gas relief devices in compressor stations. Only relief devices\non non-gas carrying equipment are exempt. Later on, Zach Barrett of the Western Region had several\nquestions about this interpretation. So we are passing along our answers, which amplify our original\nstatement.\nQuestion: Does the interpretation mean any vessel or piping in a compressor station that contains natural\ngas for whatever purpose is jurisdictional?\nAnswer: At a minimum, the interpretation applies to gas relief devices on any vessel or piping in the\ncompressor station that is used in the transportation of gas. It's unclear whether § 192.731 was intended to\ncover devices on vessels or piping that are unrelated to gas transportation by pipeline.\nQuestion: Does the gas in the aforementioned vessels or piping have to be in transportation, i.e., passing\nthrough the vessel or piping en route to the consumer before the vessel or piping is considered\njurisdictional?\nAnswer: Subpart M, and consequently § 192.731, applies to the maintenance of pipeline facilities, i.e, things\nused in gas transportation by pipeline. It doesn't matter whether the vessel or piping actually carries gas in\ntransportation. Although there may be a question whether a fuel gas line carries gas in transportation, it's\ncertainly used in transportation and, therefore, a pipeline facility.\nQuestion: Would blanket gas injected over the top of a liquid such as glycol in a tank (with a relief device)\nmake the tank and relief device subject to the regulations?\nAnswer: Yes, if the tank is used in gas transportation by pipeline. Please let me know if you would like any\nfurther assistance.\nSincerely,\nRichard D. Huriaux\nRegulations Manager\n\n<<<PAGE 2>>>\n\nDear Mr. Kent:\nThis responds to your letter of November 10, 1976, in which you ask two questions regarding the Federal gas\npipeline safety standards in 49 CFR Part 192.\nFirst, you ask whether the requirements of Sections 192.731, 192.739, and 192.743 concerning the\nmaintenance of pressure relief devices and limiting stations apply to devices and stations which are not part of\na \"pipeline\" as that term is defined in Section 192.3. As examples, you refer to devices and regulators which\nare used in gas compressor stations for purposes other than to relieve or limit gas pressure, such as devices or\nregulators on compressed air or fuel systems.\nThe word \"pressure\" in Sections 192.731, 192.739, and 192.743 restricts the applicability of those sections to\ndevices or stations which serve to relieve or limit gas pressure. The sections do not apply to devices or\nregulators which are part of non-gas carrying equipment inside gas compressor stations.\nThis interpretation is based on the relationship between the words \"pressure\" and \"gas\" occurring throughout\nPart 192 and in particular in the requirements of Section 192.192 for installation of pressure control devices.\nSince under Section 192.3 the term \"pipeline\" encompasses all the gas carrying parts of an operator's systems,\nthe pressure relief devices and limiting stations subject to Sections 192.731, 192.739, and 192.743 are those\non a pipeline.\nSecondly, you ask whether, in an aquifer storage field, gas pipelines running from the gas injection system to\ncertain water removal wells are transmission lines. Under 40 CFR 192.3, the term \"transmission line\" means a\npipeline other than a gathering line that. . . \"transports gas within a storage field.\" This definition is broad\nenough to apply to any pipeline carrying gas within the boundaries of a storage field. Therefore, since the lines\nin question are clearly not gathering lines, they are classified as transmission lines under Part 192.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations","truncated":false,"body_characters":4358}