Interpretation of §192.739 – Pressure Limiting and Regulating Stations: Inspection and Testing.

Date

Nov. 17, 2016

Purpose 

This Minnesota Office of Pipeline Safety (OPS) Alert Notice notifies gas pipeline operators about an interpretation issued to OPS by the Pipeline and Hazardous Materials Safety Administration (PHMSA). The interpretation relates to the inspection and testing of pressure limiting and regulating stations.

Applicable Code

49 CFR §192.739 — Pressure limiting and regulating stations: Inspection and testing.

Scope

This Alert Notice applies to all Minnesota intrastate pipeline operators subject to 49 CFR Part 192 with pressure limiting and regulating stations. 

MNOPS Question 

Does §192.739 require a test to physically operate ("pop") the relief device? 

PHMSA Interpretation 

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.

Requirements

Natural gas transmission and distribution pipeline companies subject to 49 CFR Part 192 are required to ensure compliance with the requirements of §192.739. As noted in the referenced interpretation correspondence, operators shall ensure that procedures, records, and training meet the inspection and testing requirements of §192.739. This maintenance function shall include physically operating the actual relief device without regard to pilot configurations. The MNOPS inspection plan will bring continued focus to this regulatory requirement.

Please contact our office if you have any questions regarding this alert notice.