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Interpretation Response #PI-71-0114 ([Fluor Ocean Services, Inc] [Mr. K.B. Lindsey])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Fluor Ocean Services, Inc

Individual Name: Mr. K.B. Lindsey

Location State: TX Country: US

View the Interpretation Document

Response text:

PI-71-0114

June 23, 1971

Mr. K.B. Lindsey
Fluor Ocean Services, Inc
Engineers Constructors
P.O. Box 36878
Houston, TX 77036

Dear Mr. Lindsey:

This is in reply to your letter of June2, 1971, concerning the application of Section 192.179 of the Federal gas pipeline safety standards, to a blow-down flare system on and off-shore platform in the Gulf of Mexico.

The system, as you have described it, is not a pressure containing part as it is open at the end and there is no way for pressure to be contained in the blow-down. Therefore, the blow down flare system downstream of the pressure controller does not require a pressure test.

It is true that §192.179 exempts offshore segments of transmission lines from having a blow-down valve. However, any component or associated piping that is part of a pipeline as defined in §192.3 (i.e. gas moves in transportation) must be designed, constructed, tested, operated and maintained in accordance with the applicable regulations even though the segment is not required by the regulations to be installed.

If we can be of any further assistance, please let us know.

Sincerely,
Original singed by:
Joseph C. Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.179 Transmission line valves