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Interpretation Response #PI-77-005 ([Panhandle Eastern Pipe Line Company] [Mr. Charles H. Kent])

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

Interpretation Response Details

Response Publish Date:

Company Name: Panhandle Eastern Pipe Line Company

Individual Name: Mr. Charles H. Kent

Location State: MO Country: US

View the Interpretation Document

Response text:

Mr. Charles H. Kent
Panhandle Eastern Pipe Line Company
P.O. Box 1348
Kansas City, Missouri 64141

Dear Mr. Kent:

This responds to your letter of November 10, 1976, in which you ask two questions regarding the Federal gas pipeline safety standards in 49 CFR Part 192.

First, you ask whether the requirements of Sections 192.731, 192.739, and 192.743 concerning the maintenance of pressure relief devices and limiting stations apply to devices and stations which are not part of a "pipeline" as that term is defined in Section 192.3. As examples, you refer to devices and regulators which are used in gas compressor stations for purposes other than to relieve or limit gas pressure, such as devices or regulators on compressed air or fuel systems.

The word "pressure" in Sections 192.731, 192.739, and 192.743 restricts the applicability of those sections to devices or stations which serve to relieve or limit gas pressure. The sections do not apply to devices or regulators which are part of non-gas carrying equipment inside gas compressor stations.

This interpretation is based on the relationship between the words "pressure" and "gas" occurring throughout Part 192 and in particular in the requirements of Section 192.192 for installation of pressure control devices. Since under Section 192.3 the term "pipeline" encompasses all the gas carrying parts of an operator's systems, the pressure relief devices and limiting stations subject to Sections 192.731, 192.739, and 192.743 are those on a pipeline.

Secondly, you ask whether, in an acquifer storage field, gas pipelines running from the gas injection system to certain water removal wells are transmission lines. Under 40 CFR 192.3, the term "transmission line" means a pipeline other than a gathering line that ... "transports gas within a storage field." This definition is broad enough to apply to any pipeline carrying gas within the boundaries of a storage field. Therefore, since the lines in question are clearly not gathering lines, they are classified as transmission lines under Part 192.


Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

Section Subject
192.731 Compressor stations: Inspection and testing of relief devices