Interpretation Response #PI-16-0009 ([Mr. Jonathan C. Wolfgram] [Minnesota Department of Public Safety])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Mr. Jonathan C. Wolfgram
Individual Name: Minnesota Department of Public Safety
Location State: MN Country: US
View the Interpretation Document
Response text:
Mr. Jonathan C. Wolfgram
Chief Engineer
Minnesota Department of Public Safety
445 Minnesota Street, Suite 147
Saint Paul, MN 55101-4145
Dear Mr. Wolfgram:
In a July 25, 2016, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 192. You specifically requested an interpretation of § 192.739 for the regulatory requirements of inspection and testing of pressure limiting and regulating stations. You asked whether § 192.739 requires a test to physically operate ("pop'') the relief device.
Yes, § 192.739 requires a test to physically operate the relief device. Section 192.739 requires inspection and testing of pressure limiting stations, relief devices (except rupture discs), and pressure regulating stations at intervals not exceeding 15 months, but at least once each calendar year. These devices must be inspected and tested to comply with § 192.739 using any practicable method that will demonstrate the presence or absence of the listed qualities. Physical operation and activation of a relief device are part of the inspection and testing. Tests must operationally activate the relief device, and demonstrate pressure control or relief at the correct pressure consistent with the pressure limits in order to comply with § 192.739. In addition, specific procedures should be documented in the operator's operating and maintenance plan prescribed by § 192.605. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
Cameron H. Satterthwaite
Acting Director, Office of Standards and Rulemaking